Tool-O

Whistleblower Policy

Tool-O is committed to promoting an ethical, lawful and transparent business environment.

1. INTRODUCTION

1.1 Purpose

Tool-O is committed to promoting an ethical, lawful and transparent business environment.

This Whistleblower Policy encourages the reporting of suspected misconduct, unlawful conduct and other serious concerns while helping to protect individuals who make reports honestly and in good faith.

1.2 Commitment

Tool-O supports a culture where concerns can be raised without fear of retaliation, victimisation or detrimental treatment for making a genuine report.

1.3 Scope

This Policy applies, where relevant, to:

employees;

contractors;

consultants;

suppliers;

service providers;

business partners;

Users;

other persons interacting with Tool-O.

1.4 Matters That May Be Reported

Reports may relate to matters including:

fraud;

theft;

corruption;

bribery;

dishonest conduct;

unlawful conduct;

serious misconduct;

breaches of Tool-O policies;

conflicts of interest;

misuse of Platform resources;

serious safety concerns;

suspected modern slavery;

other conduct that may expose Tool-O or its stakeholders to

significant risk.

1.5 Relationship with Other Policies

This Policy should be read together with the:

Code of Conduct;

Security Policy;

Modern Slavery Statement;

all other Platform policies.

1.6 Updates

Tool-O may amend this Whistleblower Policy from time to time.

The most current version published on the Platform replaces all previous versions.

2. MAKING A REPORT

2.1 Good Faith

Reports should be made honestly, in good faith and based on reasonable grounds.

Knowingly making false or malicious reports is not permitted.

2.2 Reporting Channels

Reports may be submitted through the reporting channels made available by Tool-O.

Where appropriate, reports may be made confidentially.

2.3 Information to Include

Where reasonably available, a report should include:

a description of the conduct;

relevant dates;

relevant individuals;

supporting documents;

photographs;

communications;

other information that may assist an investigation.

2.4 Anonymous Reports

Where permitted by law, Tool-O may accept anonymous reports.

Anonymous reporting may limit Tool-O's ability to investigate or provide updates.

2.5 Confidentiality

Tool-O will seek to keep whistleblower reports confidential to the extent reasonably practicable and permitted by law.

Information may be disclosed where required:

by law;

for investigation purposes;

to protect safety;

to obtain professional advice;

for other lawful reasons.

2.6 Assessment

Tool-O may conduct an initial assessment to determine:

whether the matter falls within this Policy;

whether further investigation is appropriate;

whether immediate action is required.

2.7 Investigation

Where appropriate, Tool-O may:

investigate the report;

seek additional information;

preserve relevant evidence;

engage external advisers;

refer matters to appropriate authorities where required by law.

2.8 Protection from Retaliation

Tool-O does not tolerate retaliation against any person who makes a genuine report in good faith.

Retaliation may itself result in disciplinary or other appropriate action.

2.9 Cooperation

Relevant individuals are expected to cooperate reasonably with investigations conducted under this Policy.

2.10 No Guarantee

Submitting a report does not guarantee a particular outcome or investigation result.

Each matter will be assessed based on the available information and applicable legal obligations.

3. INVESTIGATION AND RESPONSE

3.1 Fair Investigation

Where Tool-O determines that an investigation is appropriate, it will seek to investigate the matter fairly, impartially and having regard to the available information.

3.2 Investigation Process

An investigation may include:

reviewing relevant records;

interviewing relevant individuals;

examining communications;

reviewing Platform activity;

obtaining supporting documents;

seeking professional advice where appropriate;

any other reasonable investigative steps.

3.3 Cooperation

Individuals involved in an investigation are expected to:

cooperate honestly;

provide accurate information;

preserve relevant evidence;

comply with reasonable requests made during the investigation.

3.4 Confidentiality During Investigations

Information relating to a whistleblower report will be handled confidentially where reasonably practicable and permitted by law.

Confidential information will only be disclosed where reasonably necessary for:

conducting an investigation;

complying with legal obligations;

protecting individuals;

obtaining professional advice;

other lawful purposes.

3.5 Outcomes

Following an investigation, Tool-O may take action including:

no further action;

further monitoring;

internal process improvements;

policy updates;

disciplinary action where applicable;

termination of commercial relationships;

referral to law enforcement or regulatory authorities where

appropriate.

3.6 Record Keeping

Tool-O may retain records relating to whistleblower reports and investigations in accordance with applicable laws, its Privacy Policy and legitimate business requirements.

3.7 Protection of Individuals

Tool-O seeks to protect individuals involved in investigations from unlawful retaliation, intimidation or victimisation where reasonably practicable.

3.8 Malicious Reports

Knowingly false, malicious or intentionally misleading reports may result in appropriate action under applicable policies or agreements.

3.9 No Contractual Rights

This Policy does not create contractual rights, employment rights or any guarantee regarding investigation procedures or outcomes.

3.10 Continuous Improvement

Tool-O may use lessons learned from whistleblower reports to strengthen governance, risk management, compliance and ethical business practices.

4. REVIEW AND POLICY ADMINISTRATION

4.1 Policy Administration

Tool-O is responsible for administering this Whistleblower Policy and may review reports, investigations and governance processes from time to time.

4.2 Periodic Review

Tool-O may periodically review this Policy to ensure it remains appropriate having regard to:

changes in applicable laws;

business operations;

regulatory expectations;

governance practices;

lessons learned from previous reports.

4.3 Continuous Improvement

Tool-O is committed to continually improving its reporting, investigation and compliance processes to support an ethical and transparent business environment.

4.4 Compliance with Law

Tool-O seeks to comply with applicable whistleblower protection legislation and other relevant laws.

Nothing in this Policy limits any rights or protections that cannot lawfully be excluded.

4.5 No Waiver

Failure by Tool-O to enforce any aspect of this Policy at any particular time does not constitute a waiver of its rights.

4.6 Relationship with Other Policies

This Whistleblower Policy should be read together with the:

Code of Conduct;

Security Policy;

Modern Slavery Statement;

all other Platform policies.

Where there is any inconsistency, the Terms of Use prevail to the extent permitted by applicable law.

4.7 Contact

Individuals wishing to make a report or seek further information regarding this Policy may contact Tool-O using the contact details published on the Platform.

4.8 Policy Updates