Whistleblower Policy

FTFT Finance UK Ltd is committed to always conducting its business with honesty and integrity. If at any time this commitment is not respected or appears to be in question, we will endeavour to identify and remedy such situations. Where a person has reasonable grounds to believe that an employee, manager or any other person related to the company has committed, or is about to commit, an offence that could harm the company's business or reputation, we encourage them to denounce the wrongdoer in question.

This whistleblowing policy has been put in place to:

• Encourage employees, partners or managers to disclose this information or behaviour;
• Protect complainants from reprisals;
• Treat all parties to an investigation in a fair and equitable manner;
• Ensure confidentiality as much as possible;
• Take corrective and disciplinary action if wrongdoing is discovered.

The purpose of this policy is to encourage current and former employees, contractual third parties or partners to communicate events that raise serious concerns about FTFT Finance UK Ltd. We encourage and will support staff who report illegal practices or individuals who violate the organisation's policies.

This policy applies to all employees of FTFT Finance UK Ltd, as well as contractual third parties or partners doing business with the company.

It is the duty of all employees, contractual third parties or partners to report misconduct or suspected misconduct, including fraud and financial impropriety, to the board. This includes (but is not limited to):

• Providing false or misleading information, or withholding material information on financial statements, accounting, auditing or other financial reporting;
• Pursuit of material benefit or advantage in violation of our Conflict of Interest Policy;
• Misappropriation or misuse of company resources;
• Unauthorised alteration or manipulation of computer files;
• Destroying, altering, falsifying or making a false entry in records connected to an official proceeding;
• Violations of UK laws that could result in fines or civil damages, or significantly harm our reputation;
• Unethical business conduct in violation of any company policy or Code of Conduct;
• Danger to the health, safety or well-being of employees or the public;
• Forgery or alteration of documents;
• Authorising or receiving compensation for goods not received or services not performed;
• Embezzlement, self-dealing or otherwise obtaining an unlawful private benefit.

Any person who files a complaint alleging misconduct must act in good faith and have reasonable grounds to believe that the information disclosed indicates wrongdoing. No employee, third-party contractor or partner who makes a denunciation in good faith will be subject to retaliation. Anyone who retaliates against such a person is subject to disciplinary action up to and including dismissal. Allegations deemed unfounded and malicious or knowingly false may result in disciplinary action up to and including termination of employment.

A complaint may be submitted in writing to whistleblower@ftftpay.com or by post to the Compliance Officer, FTFT Finance UK Ltd, Horizon House, 136B Darkes Lane, Potters Bar, London EN6 1AF.

The written statement must include:

• Description of the offence
• Date on which you became aware of the offence
• Name of the person suspected of the offence
• Actions taken (if applicable) before filing the complaint

The complainant should expect to receive confirmation of receipt of the complaint within 5 working days. Complainants will not be dismissed, demoted, suspended, threatened, harassed or otherwise discriminated against because of the communication of a genuine concern.

All complaints will be treated in a confidential and sensitive manner. Complainants may remain anonymous, except where the nature of the disclosure or resulting investigation makes it necessary to disclose identity (e.g. judicial proceedings).

All relevant cases, including suspicious but unproven cases, will be reviewed and analysed by a competent person designated by the Compliance Officer. In some cases this may involve an investigation by a legal adviser or accountant. All investigations will be kept confidential to the extent possible. Appropriate corrective action will be taken if necessary, and findings will be communicated to the whistleblower.

Compliance Officer — whistleblower@ftftpay.com

For questions about this policy, contact us at legal@ftftpay.com.