Whistleblower Policy

1. INTRODUCTION
In order to enable our Employees and other Third Party(s) to report their concerns through a safe and reliable means, CAMP Resources Property Holdings Inc. with its subsidiaries (together referred to as “The Company” or “RCS”) has implemented this Policy, which outlines detailed procedures regarding the Company’s receipt, retention, and treatment of whistle-blower reports. Individuals who report any suspected, illegal, or unethical behaviour in good faith will be free from any retaliation or victimization for making the report.

2. OBJECTIVES AND PURPOSE
RCS management is committed to maintain open communication and trust between employees and the management, in order to achieve excellent performance in terms of Company’s operations and in compliances to the client’s expectation which is critical for the overall success of RCS. For these reasons, the Company strives to maintain a workplace where employees who have a concern for any wrongdoing of other employees, co-worker/s or managers (regardless of position) for any misconduct relating to administrative controls, violations of code of ethical standards, can be raised to the top management free of any harassment, discrimination or retaliation.
This Whistleblower Policy (“WB Policy”) replaces the previous Whistleblower Memorandum (HCD-001- 2021-014) and aligns with global best practices and applicable laws and regulations.

The purpose of this WB Policy is to:
i. Encourage employees, directors, contractors, suppliers, and other stakeholders to report genuine concerns without fear of retaliation.
ii. Provide clear guidance on what constitutes reportable concerns and the process for raising them.
iii. Ensure that all concerns are addressed/investigated promptly, fairly, and in a confidential manner.
iv. Protect whistleblowers from any form of retaliation, discrimination, or harassment for reporting in good faith.
v. Strengthen the Company’s internal controls and ethical culture by enabling early detection and remediation of potential risks.

3. APPLICABILITY
This Policy applies to any person who uses the whistle-blower channels described in this Policy in good faith. It applies to the Company, its Employees, Associate Companies and Third Parties (including suppliers, contractors, consultants, agents, and business partners who have a relationship with the Company). This Policy also applies to members of the public, where relevant. However, certain provisions outlined in this Policy are only applicable to the Employees of the Company, as specified in the Policy. This Policy is available on Company’s official website for the reference of aforementioned stakeholders.

4. SCOPE
This Policy is designed to facilitate employees and third parties to disclose any improper conduct (misconduct or criminal offence) through internal channel. Such misconduct or criminal offences include the following but not limited to:
i. Fraud, corruption, bribery, or kickbacks (actual or suspected)
ii. Theft or misappropriation of company assets or customer property
iii. Conflict of interest
iv. Financial irregularities or misrepresentation of records
v. Insider trading

vi. Abuse of authority or unethical behavior
vii. Sexual harassment or workplace harassment
viii. Health and safety violations
ix. Breach of IT security or data privacy
x. Any unlawful act whether criminal or civil
xi. Any other act that violates the Company’s Code of Conduct, Employee Handbook, or applicable laws

The above list is not exhaustive and includes any act or omissions, which if proven, will constitute an act of misconduct under RCS’s Code of Conduct and Ethics or other policies of the Company or any criminal offence under relevant legislations in force. This Policy is not to invalidate any grievance procedure and/or any disciplinary action process and procedures but to provide more avenues for employees and members of the public to disclose improper conduct committed or about to be committed to the Company.

This policy does not include social services and privileges provided by the company which include the following:

i. Employee grievances related to compensation, benefits, or performance ratings.
ii. Issues that can be addressed through existing HR grievance mechanisms.

5. DEFINITIONS
For the purposes of this Policy, the following defined terms shall mean the following:
i. Whistleblower: A person who comes forward and shares his/her knowledge on any wrongdoing which he/she thinks is happening in the whole organization or in a specific department. The person could be an employee, contractor, or a supplier who becomes aware of any illegal/unlawful activities.
ii. Protected Disclosure: A good faith communication that discloses or demonstrates information that may evidence unethical or improper activity, including but not limited to fraud, corruption, harassment, or violation of Company policies.
iii. Good Faith: A report is made in good faith when the whistleblower has a reasonable belief that the information disclosed indicates an unethical or improper activity. Reports made with malicious intent or without factual basis will be treated as false disclosures.
iv. Anonymous Reporting: The option for a whistleblower to report a concern without revealing their identity. While anonymous complaints will be accepted, the Company encourages whistleblowers to provide sufficient details to enable effective investigation.
v. Whistleblower Committee: A committee constituted by the Board of Directors to oversee the implementation of this Policy, review complaints, and ensure fair investigation.
vi. Compliance Officer means a person nominated by Board who will be part of Whistleblower Committee and responsible for receiving/handling whistleblower complaints.
vii. Employee shall mean any officers, directors or any person employed or contracted by the Company, for any work on a regular, temporary, ad hoc, or honorary basis and includes any employee, probationer, trainee by whatever name called, whether employed for remuneration or not, or working on a voluntary basis or otherwise, employed either directly or through an Agent, and any other Contingent Workers.
viii. Third Party shall mean potential or existing representatives, logistics service provider, Intermediary, Suppliers, Advisors, Truckers, Agents, Design Partners, Custom Brokers, Consultants, Associated Persons, Business Partners of the Company and includes those employed, acting on behalf of, under the supervision or jointly with the Company.
ix. Retaliation: Any adverse action taken against a whistleblower for reporting a concern in good faith,

including but not limited to harassment, demotion, termination, or discrimination.

6. PROTECTED DISCLOSURES
i. A Protected Disclosure refers to any good faith report made by an employee, director, or third party that discloses or demonstrates information which may indicate unethical or improper activity, including violations of law, Company policies, or ethical standards.
ii. The Company encourages Whistleblowers to provide sufficient details to enable effective investigation. Reports should include, wherever possible, the nature of the concern, names of individuals involved, dates, locations, and any supporting evidence or source of evidence. Disclosures may be submitted in English or Filipino or any other language through any of the reporting channels specified in this policy.
iii. Protected Disclosure should be written to provide clear understanding of the issues raised and should either be typed or written in a legible handwriting in English or Filipino or any other language. A Whistleblower may receive a Monetary Reward depending on the gravity/bearing of the offence being reported.
Disqualification of Protected Disclosure:
The Company reserves the right not to investigate a protected disclosure in the following circumstances:
• The matter reported does not fall within the scope of this policy; or
• The disclosure lacks minimum information such as location of incident, timing, personnel involved, specific evidence or source of evidence, and a clear description of the incident.
In cases where a disclosure is summarily dismissed, a record of such cases will be maintained and presented to the Whistleblower Committee/Board of Directors on a quarterly basis. The Committee/Board may request additional details or direct that an investigation be initiated in any matter previously dismissed.

7. REPORTING CHANNELS
i. The Company has established multiple secure channels for reporting Protected Disclosures/concerns under this Policy as mentioned below:

Email
• The Whistleblower can make a Protected Disclosure by emailing his/her concerns to the Whistleblower Committee through the dedicated email address
<wb@royalecoldstorage.com.ph>. The reporting channel will be managed by the Compliance Officer / HR Representative and will be overseen by the Legal Head / HR Head.
• Any Employee or Third-Party can also report a Protected Disclosure to their respective reporting manager or HR department in an oral or written format. Such manager or HR department needs to convert the oral complaint into a written complaint and immediately forward the written complaint from a Whistleblower to <wb@royalecoldstorage.com.ph>.

ii. The authority to access the Protected Disclosures being made through any of the above Whistleblower complaint channels would rest with Compliance Officer/HR Representative.
iii. The Compliance Officer/ HR Representative shall ensure that the policy and the Whistleblower reporting channels are duly communicated to all concerned to ensure that the potential Whistleblowers are aware of the policy and reporting channels.

iv. If the Whistleblower believes that the matter cannot be appropriately addressed by any of the above reporting channels then the report may be escalated to the President at jpangilinan@royalecoldstorage.com.ph or the Chief Executive Officer at fctongson@royalecoldstorage.com.ph.
v. Nothing in this Policy in any way prohibits or is intended to restrict or impede Employees or Third Party from exercising protected rights or otherwise disclosing information to law enforcement agencies, regulatory, or administrative agencies as permitted by law.

8. ANONYMOUS COMPLAINTS
i. Subject to applicable laws and regulations, when using one of the reporting channels, you are encouraged to identify yourself. However, anonymous complaints can be made subject to applicable laws and regulations.
ii. Making a complaint anonymously may affect that whistle-blower’s ability to receive feedback on the status of any investigation, if any, and may affect our ability to investigate the matter or offer protection to the whistle-blower. Anonymous whistle-blowers are particularly encouraged to provide as much information and evidence as possible.

9. NO RETALIATION
i. The Company is committed to ensuring that Whistleblowers are protected from any form of reprisal or retaliation for reporting concerns in good faith. Retaliation includes, but is not limited to, discrimination, harassment, hostility or victimization in any manner. The Whistleblower will not suffer loss in any other manner like, transfer, demotion, denial of promotion, or any action that adversely affects the whistleblower’s employment or engagement including making further Protected Disclosure, as a result of reporting under the policy.
ii. This protection is available provided that:
o The disclosure is made in good faith; and
o The Whistleblower is not acting for personal gain.
iii. Any other Employee or Third-Party personnel assisting in an investigation raised by the Whistleblower will receive the same level of protection as the Whistleblower.

iv. If any Employees or Third Party comes across any retaliation, it needs to be reported to the
Compliance Officer at the earliest.

v. This Policy does not prevent any Employees or Third Party of the Company of the consequences of their own misconduct while making any whistle blower complaint and will face disciplinary actions for the misconduct they have engaged in.

10. CONFIDENTIALITY
Subject to applicable laws or regulations, Employees and Third Party(s) can submit whistle-blower complaint anonymously (meaning that the identities of the complainant will not be known by anyone) and/or confidentially (identities and complaints will be disclosed only to those who need to know about the investigation, remedial actions or under applicable laws), subject to the following conditions:
i. Prior written consent is to be taken by the Employees and Third Party (s) for disclosing their identity

only for investigation purpose.
ii. Persons in the investigating team to whom the identity of the Employees and Third Party (s) are being disclosed make a written assurance not to disclose the identity of the Employees and Third Party.
iii. Witnesses participating in the investigation will also be instructed to maintain confidentiality.

11. MANAGING WHISTLEBLOWER INVESTIGATIONS AND REPORTS
INVESTIGATIONS
i. All complaints made under this Policy will be promptly and thoroughly investigated by the Whistleblower Committee, or by other teams under their supervision. The specific action taken in any case depends on the nature and gravity of the conduct or circumstances reported and the results of the investigation. The Whistleblower Committee shall comprise of Compliance Officer, Legal Head and HR Head.
ii. If misconduct has been confirmed through an investigation, the Company will take prompt and appropriate remedial action proportionate to the seriousness of the misconduct, in accordance with its suggested guidelines. Such remedial action may include disciplinary action against the accused party, up to and including termination of employment. Reasonable and necessary steps will also be taken to prevent any further occurrence of misconduct.
iii. All Employees and Third Party are expected to cooperate fully and honestly with any internal investigation. Any Employees who fail to cooperate (e.g., by not providing complete and truthful information or knowingly provides misleading information) will be subject to disciplinary action.
iv. When possible appropriate notice of the status of the investigation may be provided to the whistle- blower. Given the sensitive nature of many investigations arising from whistle-blower reports and certain limitations under applicable laws, we do not commit to provide whistle-blowers with an update or outcome of an investigation. Specific guidance will be provided on a case-by-case basis.
v. To the extent allowed or required by law, information reported may be communicated to public bodies or authorities competent for the prosecution of crimes. In doing so, the Company will strive to maintain the confidentiality of the identity of the whistle-blower.
vi. The investigation shall normally be completed within Thirty (30) days of receipt of the Protected Disclosure/Complaint. For complicated matters, the investigation team may unanimously agree to extend the investigation period, provided that the extension shall not exceed ninety (90) days.
REPORTING
i. Every quarter the Legal Head/HR Head shall submit a report to the Board of Directors to show specifically:
a. The Subject and the Whistleblower (unless anonymous, in which case the report will so indicate);
b. A description of the complaint;
c. The status of the investigation;
d. Any conclusions reached by the investigator; and
e. Findings and recommendations.

ii. This shall be in addition to the list that Legal Head/HR Head is required to submit to the Board of Directors for summary dismissals.

iii. All reports made after the investigation or for the complaints received, will be adequately recorded which is to be reviewed by the Chairman/CEO every year (may be modified).

12. LEGAL COMPLIANCE
This Policy seeks to establish guidelines and provide the basis for developing standards in consideration of applicable laws. If any part of this Policy conflicts with any of the applicable law, such applicable laws would prevail and if any guidance is required, in that scenario Employees must seek guidance from Compliance Officer before taking action.

13. TRAINING AND AWARENESS
Every Employee, Third Party including the Senior Management of the RCS is responsible for being familiar with this Policy for which Compliance Officer will take steps to ensure all the aspects of this Policy is communicated effectively and an appropriate training program is put in place. All Employees, Third Party including the Senior Management will be required to participate in the training sessions held at least once a year and should familiarize themselves with this Policy on their specific responsibility to evaluate and effectively address any issues or violations.

The Training and Organizational Development (TOD) Department of RCS will be responsible for conducting and facilitating the trainings, in coordination with the Compliance Officer and the respective stakeholders.

14. DISCIPLINARY ACTIONS
• Any Employee, representative, Third Party who knowingly makes false allegations of unethical or improper practices, or violates the regulations of this Policy, or any related procedures, shall be subject to appropriate disciplinary action, up to and including termination of employment, loss of compensation, business relationship or other measures deemed appropriate by the Company.
• Also, any Employee or Third Party who engages in any kind of retaliation towards Whistleblower will also be subject to disciplinary action, up to and including termination of employment or business relationship, in accordance with Company rules, policies and procedures.

15. DOCUMENTS RETENTION
• The Company shall retain all protected disclosures in writing or documented along with the results of investigation for a minimum period of seven (7) years or any other relevant period required under law.

16. AMENDMENTS AND REVIEW
• The Company has the right to amend, suspend or replace this Policy anytime and shall inform Employees, Third Parties, and any other representatives of such amendment in due course.
• The Company may also establish further rules and procedures, from time to time, to give effect to the intent of this Policy.