1. Introduction

In October 2019, the European Parliament and Council passed EU Directive 2019/1937 (the "Directive") setting out requirements for the protection of whistle blowers and acknowledging the importance of providing balanced and effective whistle blower protection. The Policy sets out Litostroj Group’s responsibilities and commitments towards whistle blower protection.

2. Definition

The European Union defines whistle blowers as “persons who report (within the organisation concerned or to an outside authority) or disclose (to the public) information on a wrongdoing obtained in a work-related context, help preventing damage and detecting threat or harm to the public interest that may otherwise remain hidden”.

For the purposes of the Policy, a whistle blower can be a former, current or prospective partner, director, officer, manager, employee, legal representative of an employee, supplier, contractor, volunteer or intern of any Group company.

A whistle blower is protected under the Policy (together with certain related persons described in section 6 below) if he/she learns about possible illegal activities (or other material wrongdoing) in any of the following areas:

• Any crime or offence.
• Abuse of power.
• Anti-competition.
• Breach of EU or other relevant authorities state aid rules.
• Breach of the Code of Conduct and company policies.
• Conflict of interest.
• Corporate taxation.
• Customer protection (including product safety and compliance).
• Discrimination.
• Environmental protection (including animal health and welfare).
• Financial services including accounting and internal controls.
• Harassment, bullying and sexual misconduct.
• Health and safety (including public health protection).
• Human Rights abuses.
• Improper use of company assets.
• Insider trading.
• Personal data protection and privacy.
• Security of networks and information systems.
• Procurement law.
• Protection of the EU’s financial interest.
• Protection of public order and internal security.

Concerns regarding poor performance by a whistle blower are treated through that person’s supervisor, the applicable Human Resource Department and/or the Procurement Department. Other work-related grievances are dealt with through the internal grievance mechanism procedure. Concerns regarding external stakeholders, such as communities, are treated through the stakeholder grievance mechanism procedure.

3. Objectives

The objectives of the Policy are:

• To comply with the Directive, any national law into which it is transposed and any other laws binding on Group companies in respect of whistle blower protection (including, in respect of Canada, relevant Canadian and Quebec laws).
• To protect people who report breaches (meaning possible illegal activities or other material wrongdoing, as described above) which they have learned about in connection with their work.
• To prevent retaliation towards whistle blowers and other persons (as described in section 0 below).

4. Reporting Procedure

People wishing to report breaches under the Policy must follow the following procedure:

A. Contact the Whistle Blower Policy designated person (“WBDP”) named in section 5 below using any means set out in Annex 1. Persons wishing to remain anonymous must say so in the first contact with the WBDP.

B. The WBDP will note the key points of concern and request documentary evidence, if available. The whistle blower must provide as much detail as possible. Useful data to provide includes:

• Nature of concern.
• Date, time and location.
• Name of each relevant person, together with his/her role and department.
• Relationship to the relevant person.
• How information about the concern was obtained.
• Witnesses.
• Other relevant information to support the report (e.g., documents, photos, etc.).

C. The WBDP will acknowledge receipt of each report within 7 days and thereafter conduct an initial investigation, seeking any required support from relevant offices and/or sites. If contact with different offices/sites is required, the WBDP will ensure that the people supporting the investigation are aware of the provisions of the Policy and the requirement to protect the whistle blower, including prevention of any form of retaliation.

D. Depending on the subject matter of the report and the supporting evidence available, the WBDP will conduct a thorough investigation. Internal and external legal advice will be sought, if required. The investigation will:

• Follow a fair process.
• Be confidential (including by its non-accessibility to non-authorised staff members).
• Be conducted efficiently and without delay.
• Determine if there is sufficient evidence to establish the truth of the alleged acts or omissions.
• Be independent of people connected with the alleged facts.
• Presume the innocence of the relevant person until the investigation is complete.

E. The WBDP will prepare a report detailing the subject matter of the report and the results of the investigation. The Report will be provided to the Board of Directors (“BOD”) for its approval together with a summary of its key findings and a proposed course of action.

F. The WBDP will inform the whistle blower of the results of the investigation and the course of action approved by the BOD within 30 days after the WBDP acknowledges receipt of the initial report. It is possible to postpone the deadline by up to 30 days, once or twice, but in each case the whistle blower must be informed, together with reasons for the postponement, before the deadline expires.

Additional Information for the whistle blower:

A. Whistle blowers should ensure that they have reasonable grounds to suspect conduct that warrants reporting. In reality, a mere allegation without evidence or other supporting information will be unlikely to prove any wrongdoing, however a whistle blower need not prove the allegation to any legally recognised standard.

B. If the whistle blower knowingly provides false or misleading information, this could result in disciplinary action and/or other legal consequences.

C. Litostroj Group will protect the identity of the whistle blower, subject to lawful disclosures.

D. If the whistle blower suffers any type of retaliation following a report, he/she must inform the WBDP immediately.

E. Physical and legally obtained electronic (including audio-visual) records of reports, conversations and meetings created pursuant to the Policy, and other materials connected with any investigation of a report, will be retained for a reasonable and proportionate period, having regard to applicable laws governing whistleblowing, data protection and so on.1 All records must be securely stored to protect their confidentiality and integrity.

F. A whistle blower can make an external report to any public agency established in accordance with the Directive or other applicable and binding laws (an “external channel”), details of which are set out in Annex 2, however he/she is encouraged first to use the internal reporting procedure created pursuant to the Policy, being the simplest, most secure and most effective way to address the subject matter of a report.2

G. A whistle blower must make a report through the WBDP, or an external channel, to qualify for protection against retaliation under the Policy.

5. Designated Person

Subject to the next following paragraph, the WBDP is named in Annex 3.

If the whistle blower suspects that the relevant WBDP is involved in the possible irregularity or if there is no response to the report within 7 days after it is made, the report must be sent (or resent) to the management of the company.

6. Litostroj Group Commitment

Litostroj Group commits to investigating all issues brought forward through the whistle blower process and to treat all people making reports with respect and free from harassment and retaliation. Like protection will be afforded to the WBDP, any facilitator or connected person of a whistle blower (such as co-workers and relatives) and/or any legal entity which the whistle blower owns or works for.

1 In Canada this includes maintaining records for at least five years, in compliance with directives of the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) and other Canadian regulatory requirements.

2 In Canada, to ensure compliance with their duty of loyalty to their employer when making an external disclosure, a whistleblower must meet the following conditions:

• ensuring that the information disclosed is truthful;
• acting in good faith (e.g. not being motivated by revenge);
• disclosing only information that is of public interest;
• having exhausted internal remedies (if any); and
• ensuring that the scope of the external disclosure is not disproportionate to the objective pursued.

The identity of a whistle blower will remain confidential. The WBDP will discuss the topic with the whistle blower and obtain her/his explicit consent prior to disclosing his/her identity. However, there are specific legal exceptions where the identity of a whistleblower may need to be disclosed without consent. These exceptions include, but are not limited to:

• compliance with a court order or legal requirement; and
• situations where it is required by law to disclose the identity to law enforcement agencies or other regulatory bodies.

In all cases where disclosure of the whistleblower’s identity is necessary, the whistleblower will be informed of the disclosure, unless prohibited by law.

Litostroj Group will not initiate, and will not tolerate, any form of retaliation against a whistle blower.

Examples of retaliation can include:

• Dismissal.
• Demotion.
• Reduction of salary.
• Reduction or increase in working hours.
• Job transfer without consent.
• Lack of access to promotions or capacity-building opportunities.
• Negative job performance evaluation that does not reflect actual performance.
• Harassment, intimidation, threats and/or bullying.

7. Data protection

Annex 4 describes the rights of Group companies to process as a data administrator the personal data of employees and individual associated persons reporting irregularities (as defined above) or involved in any internal investigation triggered by such a report.

8. Entry into Force

This version of the Policy enters into force and is effective on and from 1 June 2026 and replaces in full any earlier version of the Policy.

Annex 1 Means of making report

You can make a report under the Policy (or otherwise contact the WBDP) in any of the following ways:

• Mail as determined in Annex 3,
• Email as determined in Annex 3,
• telephone: as determined in Annex 3
• in person: by appointment (within 7 calendar days after the request)

Verbal communications made during a face-to-face meeting shall be documented by a recording of the same in a secure, durable and accessible format or by an accurate and complete transcript. This is without prejudice to the whistle blower’s rights under data protection legislation and his or her opportunity to verify, rectify and agree to the transcript of the conversation by signing it.

Annex 2 Contact details for external reporting channels

For Canada

1. For issues related to money laundering and terrorist financing:

Financial Transactions and Reports Analysis Centre of Canada (FINTRAC): https://fintrac-canafe.canada.ca/intro-eng

2. For criminal offenses (e.g., corruption, fraud):

Contact your local law enforcement.

For Quebec only

3. For issues related to a Quebec’s public body:

Protecteur du Citoyen: https://protecteurducitoyen.qc.ca/en/whistleblowers/how-to-disclose-a-wrongdoing (on-line or by telephone: +1-800-463-5070)

4. For issues related to labour standards, workplace equity, health, and safety:

Commission des normes, de l'équité, de la santé et de la sécurité du travail (CNESST): https://www.cnesst.gouv.qc.ca/en/client-services/complaints-recourses

5. For issues related to financial market regulation, including fraud:

Autorité des marchés financiers (AMF): https://lautorite.qc.ca/en/general-public/assistance-and-complaints/whistleblower-program

6. for issues related to non-compliance with environmental laws (e.g., waste management, pollution, etc.):

Ministère de l’Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs: https://www.environnement.gouv.qc.ca/formulaires/Plainte/avis_signalement_p1.asp

For Czech Republic

Ministry of Justice

1. in writing:

via the form available here: https://whistleblower.justice.cz/chci-podat-oznameni/

by email: oznamovatel@msp.justice.cz, mnetocny@msp.justice.cz

by mail: Vyšehradská 16, Prague 2, Postal Code 128 10

by telephone: +420 221 997 840

2. orally:

on site at the Ministry of Justice of the Czech Republic at the address: Vyšehradská 16, Prague 2, Postal Code 128 10

For Slovenia

Reporters may also make an external report of a violation directly to the competent authorities in the area in which the violation they wish to report occurred. An external report is considered if an internal report cannot be effectively handled, or if the reporter believes that there is a risk of retaliation in the event of an internal report.

Contact for external channels: https://www.gov.si/teme/zascita-prijaviteljev/

For USA

For issues related to unsafe or unhealthful conditions:

U.S Department of Labor, Occupational Safety and Health Administration (OSHA)

1. In writing

via the form available here: https://www.osha.gov/whistleblower/WBComplaint

by fax: (205) 731-0504 (Birmingham OSHA Area Office)

2. orally:

on site at Birmingham OSHA Area Office, Medical Forum Building 950 22nd Street North, Room 1050, Birmingham, AL 35203

by telephone: +1 205 731-1534 (Birmingham OSHA Area Office)

Annex 3 Contact details for alternative WBDP

For Canada

Mr. Philippe Rousseau

Email: philippe.rousseau@litostrojhydro.ca

telephone: +1 (514) 515-9369

Adress: 5025 boul. Lapinière, bureau 100, Brossard (Québec), J4Z 0N5, Canada

For Czech Republic

Mrs. Vendula Kolaříková

Email: vendula.kolarikova@litostrojpower.com

telephone: +420 739 790 805

Adress: Technická 3029, 616 00 Brno - Královo Pole, Czech Republic

For Slovenia

Mr. Timo Rozman

email: zaupnik@litostrojpower.eu

telephone: +386 51 634 644

Adress: Litostrojska cesta 50, 1000 Ljubljana, Slovenia

Other: mailbox on the ground floor of the administration building in front of the entrance to the canteen

For USA

Mr. Anthony Costantini

email: a.costantini@litostroj-us.com

telephone: +1 205-751-9392

Adress: 2204 Lakeshore Dr Suite130, Birmingham, AL 35209, USA

Annex 4 Data Protection

Purpose of Data Processing:

Personal data of employees and individual associated persons who make a report under the Policy or are involved in any proceedings initiated to determine whether an irregularity took place may be processed by the relevant Group company as a data administrator.

The purpose of processing will be to determine whether an irregularity took place, the risks of the same to the Group and further legal measures, including reporting bribery or money laundering to relevant law enforcement bodies.

Legal Basis for Data Processing:

The relevant Group company will process personal data on the basis of the legally justified interests of the data administrator, except where the interests or fundamental rights and freedoms of data subjects have an overriding nature.

Rights of Data Subjects:

Persons whose personal data is processed as described above will have the right to request the relevant Group company to grant them access to such personal data and to correct, delete, limit the scope of the data processing or object to the data processing. The above- mentioned rights are subject to limitations stipulated by applicable law. Data subjects will also have the right to file a complaint with any relevant public authority responsible for the protection of personal data.

Personal data that is processed as described above may be forwarded to persons rendering legal assistance or forensic audit services to the relevant Group company or for the purpose of collecting evidence in accordance with generally binding law. No personal data originating within the European Economic Area will be forwarded outside the European Economic Area.

Duration of Data Processing:

Personal data that is processed as described above will be processed for the periods permitted or required by generally binding law or until expiry of any applicable statute of limitations.

Additional Data Protection and Cross-Border Communication Notice (Applicable to Canada and Quebec Only):

In accordance with the Act respecting the protection of personal information in the private sector in Quebec (“ARPPIPS” or “Law 25”), the Policy ensures that personal data is handled with the highest privacy settings by default and maintains full transparency regarding the purposes of data collection, retention periods, and any disclosures to third parties.

Furthermore, this section serves as a specific notice to all employees and associated persons who make reports under the Policy, concerning the processing and potential communication of personal data outside of Quebec and Canada, in compliance with local data protection legislation.

Cross-Border Data Communication:

In accordance with the transparency obligations set by paragraph 2 of section 8 of Law 25 and applicable Canadian privacy laws, individuals are hereby informed that their personal data collected under the Policy may be communicated outside of Quebec and Canada. Such communications may occur when engaging with external legal services, forensic audit services, or as mandated by applicable law.

The relevant Group company must ensure that all data transfers adhere to legal requirements and that appropriate safeguards are implemented.