Testlio Whistleblower Policy

Testlio Inc. and its group entities/companies (hereinafter “Testlio”) is committed to conducting business with honesty and integrity. We expect all Employees, Contractors and Freelancers to maintain high standards in addition to complying with the local laws, our policies and procedures. That said, we also understand that there is a possibility for things to go wrong.

The purpose of this policy is to:

• Provide Employees, Contractors and Freelancers with guidance on whistleblower policy;
• Provide transparency on receiving, handling and investigating whistleblowers incidents;
• Encourage Employees, Contractors and Freelancers to report any suspected instances of wrongdoing as quickly as possible;
• Assure Employees, Contractors and Freelancers that their concerns will be taken seriously, investigated timely in an appropriate and confidential manner;
• Provide Employees, Contractors and Freelancers with guidance on how to raise concerns;
• Meet Testlio’s legal and regulatory obligations;
• Support Testlio’s reputation and long-term sustainability.

This policy is intended to enable those who become aware of wrongdoing within Testlio to report their concerns at the earliest opportunity so that the suspicions can be properly investigated.

The Whistleblowing Policy is not intended to replace existing procedures, and therefore you should bear in mind:

• If your concern relates to your own treatment (as an Employee, or a partner) we encourage you to proceed through existing channels, such as through your direct manager, or People & Culture team;
• If a customer has a concern about the services provided, we encourage them to reach out to us at speakup@testlio.com.

However, if you feel your complaint cannot be resolved through existing procedures, or you feel you require additional protection or confidentiality, then it would fall within the scope of this policy.

Communication of this policy

Employees, Contractors and Freelancers are introduced with Whistleblower Policy during the overall onboarding. TestLions are notified and required to read the policy at least once a year even if any changes are not made to the policy. When changes are made all TestLions are notified and required to read Whistleblower Policy.

An up to date Whistleblower Policy for Employees is always available in Testlio’s internal Confluence page. For Contractors and Freelancers an up to date Whistleblower Policy is always available at the Intercom Help Center.

Review of the policy

Testlio will review Whistleblower Policy annually and the People & Culture team will report on whistleblowing to the Board annually.

Whistle Blowing

Whistle blowing is the disclosure of information which relates to suspected wrongdoing (generally a breach of a legal, statutory or regulatory requirement, or unethical, immoral behavior). This may include disclosures related to:

• Conduct which is an offense or a breach of the law;
• A failure to comply with any legal obligations;
• Miscarriages of justice;
• Risks to the Health and Safety of the public and/or other Testlio Employees;
• Unauthorized use of funds or other assets;
• Possible fraud and corruption;
• Neglect or abuse of customers or partners;
• Discrimination;
• Harassment;
• Abuse of power and authority for personal gain;
• Damage to the environment, which is already committed or is likely to be committed;
• Gross mismanagement or waste;
• Deliberate concealment of the aforementioned information;
• Other unethical or illegal conduct.

TestLions can and should always voice their concerns. If you have any genuine concerns to any of the above, you should report it under this policy.

Protection for the whistleblower

Disclosures made under Whistleblower Policy are protected disclosures. This means it will be a disclosure of information which, in your reasonable belief, tends to show that one or more wrongdoings, has been, is being or is likely to be committed.

Testlio assures that no one will be dismissed or victimized on the basis of their appropriate lawful disclosure in accordance with the Whistleblowing Policy that they have made.

Testlio will also protect whistleblowers from suffering any damage, ensuring that whistleblower is not subject from any of the following:

• Dismissal or injury of a TestLion in his or her employment;
• Alteration of TestLion’s position or duties to his or her disadvantage;
• Discrimination between TestLion and other TestLion of the same employer;
• Harassment or intimidation of a person;
• Harm or injury to a person, including psychological harm;
• Damage to a person’s property;
• Damage to a person’s reputation;
• Damage to a person’s business or financial position;
• Any other damage to a person.

Damage does not include redeployment of the whistleblower’s working position through the course of the investigation, moving a whistleblower to another team or group entity in order to protect them.

In addition, Testlio will not enforce a contractual or other remedy, or exercise a contractual or other right, against you as a whistleblower on the basis of a disclosure under Whistleblower Policy.

In rare instances, it may be the case that the reporting TestLion has themselves participated in the action that has caused concern. In these cases Testlio reserves its rights at law, but the fact that the reporting person came forward may be taken into account.

Confidentiality

All disclosures under this policy will be treated in confidence. In case you wish to remain anonymous, every effort will be made not to reveal your identity or information that is likely to lead to your identification.

If further action is required as a result of your disclosure, it may be necessary for you to be asked to come forward as a witness, with your prior agreement.

In order to ensure the whistleblowers’ confidentiality, Testlio will take the following measures:

• When possible, all personal information or reference to the whistleblower witnessing an event will be redacted;
• The whistleblower will be referred to in a gender-neutral context;
• All paper and electronic documents and other materials relating to disclosures will be stored securely;
• Access to all information relating to a disclosure will be limited to those directly involved in managing and investigating the disclosure;
• Only a restricted number of people who are directly involved in handling and investigating a disclosure will be made aware of a whistleblower’s identity (subject to the whistleblower’s consent) or information that is likely to lead to the identification of the whistleblower;
• Communications and documents relating to the investigation of a disclosure will not to be sent to an email address or to a printer that can be accessed by other staff;
• Each person who is involved in handling and investigating a disclosure will be reminded about the confidentiality requirements, including that an unauthorized disclosure of the whistleblower’s identity may be a criminal offense.

Anonymous Allegations

This policy encourages you to put your name to your allegation if possible – concerns expressed anonymously can result in it being more difficult for Testlio to protect you, your position, or to give your feedback.

Concerns expressed anonymously may still be considered at the discretion of the recipient of the disclosure. In exercising this discretion the factors to be taken into account would include:

• The seriousness of the issue raised;
• The credibility of the concern, and;
• The likelihood of confirming the allegation from other sources.

Untrue Allegations

If you make an allegation in good faith and reasonably believe it to be true, but it is not possible to confirm the allegation through the investigation, then Testlio may recognize your concern and confirm that no further action will be taken.

However, if it is found that you have made an allegation frivolously, maliciously or for personal gain, we will respond accordingly and potentially with disciplinary action.

Raising a concern

• All such reports will be treated with confidentiality. Reports can be emailed to speakup@testlio.com;
• In case you wish to submit a disclosure anonymously, you can fill in the Whistleblower Google Report Form.

You should make it clear that you are making your disclosure within the terms of Testlio’s Whistleblowing Policy. This will ensure the recipient of the disclosure realizes this and takes the necessary action to investigate the disclosure and protect your identity.

The recipient of the disclosure will then get in touch with you to discuss your concern. We will aim to keep you informed of the progress of the investigation and the likely timescale. However, sometimes the need for confidentiality may prevent us from giving you specific details of the investigation or any disciplinary action taken as a result.

Testlio actions

Testlio will respond to your concerns as quickly as possible within a reasonable timeframe.

Please bear in mind that investigations of serious allegations may take time.

To assure fairness to all TestLions, including those who may be wrongly or mistakenly accused, initial enquiries will be made to decide whether an investigation is appropriate, and if so, what form it should take.

Confidentiality may be required for the term of the investigation, meaning that the subject of the complaint may not be informed of the process.

Where appropriate, a matter raised may:

• Be investigated internally, for example by the People Ops team. In case of escalation it may be investigated by the ELT team;
• Be referred to the police or other relevant authority;
• Be referred to an alternative appropriate external body, or industrial tribunal.

Within a reasonable time frame of a concern being raised, the person investigating your disclosure will:

• Acknowledge that the disclosure has been received;
• Indicate how Testlio proposes to deal with the matter;
• Supply you with information on staff supporting mechanisms;
• Tell you whether further investigations will take place and if not, explain why not.

The amount of involvement you will have during the investigation will depend on the nature of the matters raised, the potential difficulties involved, and the clarity of the information provided. It is possible that you will be interviewed to ensure that your disclosure is fully understood.

Testlio will take any possible actions to minimize any difficulties that you may experience as a result of raising a concern.