INTRODUCTION

At Actylis, we are committed to conducting business with integrity and the highest ethical standards. We are committed to creating a safe and positive environment for all of our team members, as well as those who conduct business with Actylis. These standards are most important to us, and this Speak Up policy demonstrates Actylis’ commitment to these values.

It is important that all Actylis team members behave in an exemplary manner that demonstrates our commitment to these principles, which can be found in Actylis’ employment policies and its Code of Ethics.

We all have a role to play in supporting the values set forth herein. During your employment, you may observe or experience conduct which you believe violates the law, Actylis’ Code of Ethics, or other Actylis policies and procedures. If you witness any such behavior, you are encouraged to Speak Up.

The purpose of this Speak Up Policy is to help promote the highest ethical standards. Actylis maintains a workplace that encourages and facilitates the reporting of potential violations of its Code of Ethics, company policies, and applicable laws or regulations. Any employee, customer, visitor, vendor, contractor, or any other third party working with or on behalf of Actylis may raise concerns regarding potential violations without fear of retaliation or retribution. This policy further explains when, where, and how a concern about suspected misconduct can be made in confidence, and what to expect from Actylis after such a concern is raised.

SCOPE

The Speak Up Policy can be used to raise any concerns about violations or potential violations of Actylis’ Code of Ethics, company policies, and applicable laws or regulations. Examples of such concerns include, but are not limited to, the following:

• Harassment, discrimination, hostile work environment or bullying
• Issues pertaining to human rights or fundamental freedoms
• Health, safety or security issues
• Retaliation
• Conflicts of interests
• Matters related to Actylis’ corporate reputation and integrity
• Violation of the law or regulations
• Failure to follow company policies or procedures
• Fraud, theft or other misappropriation
• Environmental or social injustice
• Accounting or financial reporting irregularities
• Bribery, corruption, inappropriate receipt or solicitation of gifts or hospitality
• Breaches of Actylis’ Code of Ethics

MAKING A SPEAK UP REPORT

Anyone who wishes to make a Speak Up report may do so as follows:

• Reporting through the secure Actylis Speak Up website: https://speakup.actylis.com/

Anyone who receives information which might constitute a Speak Up report, who is not otherwise authorized to act on such a report, should contact the local HR representative so that the information may be properly investigated.

Speak Up reports may be made anonymously through the secure Actylis Speak Up website: https://speakup.actylis.com/. Actylis’ ability to investigate and resolve an issue reported anonymously may be limited by the detail and sufficiency of the information provided by the reporter.

Actylis encourages reporters to make their identity known when making a Speak Up report to ensure that the report can be thoroughly investigated. The reporter’s identity will be kept confidential in accordance with this policy and will not be disclosed to the accused unless otherwise required by law or if the reporter provides explicit consent.

When making a Speak Up report, the reporter should provide as much detail as possible. Among the details that should be reported are:

• Where and when the subject of the report occurred, including how the incident violates (or may violate) the Speak Up policy.
• Whether the reporter has direct first-hand knowledge of the subject of the report or if it was received through another source.
• The identity of any other individual(s) who may have witnessed the incident.
• Whether there are any documents, emails, text messages, photographs, video recordings, audio recordings or any other tangible material that may substantiate the subject of the report.
• Contact information for the reporting party.
• Whether there are any documents, emails, text messages, photographs, video recordings, audio recordings or any other tangible material that may substantiate the subject of the report.
• Contact information for the reporting party.

THE INVESTIGATION PROCESS

Once a Speak Up report is made, Actylis will activate its investigative process. That process includes the following steps:

• Initial Assessment: All reports are evaluated to determine whether the report concerns a matter to be addressed pursuant to the Speak Up policy.
• Assignment and Investigation: All reports that fall under the Speak Up policy will be assigned to an investigator, and an investigation will be conducted. This may include interviews with the reporter and potential witnesses and a review of any available data. During the investigation, steps will be taken to ensure that confidentiality is maintained to the extent possible, and as permitted/required by law.
• Determination and Findings: Upon completion of the investigation, the investigator will summarize his/her findings and create a determination report.
• Action: The determination report will be shared with the appropriate parties (supervisors/managers, Human Resources, Legal) and remedial action taken, where appropriate.
• Conclusion: Upon the implementation of remedial action, if any, or upon the determination that the report is unfounded, the investigator will close the investigation and notify the reporter of the closure of the matter.
• Follow-Up: Where remedial measures are implemented, those measures will be monitored to ensure compliance, and follow-up communication may occur with the reporter to determine if additional action is required. While a reporting party may receive follow-up communication, there may be limits to the extent of information that may be shared with the reporting party.

If contacted regarding an investigation, employees are expected to cooperate and answer any questions fully and truthfully. Providing false information or intentionally omitting information may lead to disciplinary action up to and including discharge. Interfering with or refusing to cooperate with an investigation may also lead to disciplinary action up to and including discharge.

If you learn about or participate in an investigation, you are expected to maintain the confidentiality of the investigation and any information that you provide during the investigation.

NO RETALIATION

No one will be retaliated against for making a Speak Up report or for participating in an investigation of a Speak Up report. Retaliation is strictly prohibited by this policy. Retaliation can take many forms. While some retaliatory actions may be obvious (i.e., discharge, demotion, reduction in pay, reassignment of projects), others may be less so (ignoring someone, making work conditions uncomfortable). Retaliation is any action, consequence or punishment that is imposed on a person for having reported or participated in a Speak Up incident or for refusing to engage in behavior that would violate this policy.

If you have made a Speak Up report or have participated in a Speak Up investigation and feel you are the target of retaliation, you should report this immediately. Anyone engaging in retaliatory conduct will be subject to discipline, up to and including discharge.

MISUSE OF THE SPEAK UP POLICY

Anyone who knowingly reports false information to the Speak Up reporting resources may be subject to discipline up to and including discharge.