MontageMontage

Whistleblower Policy

1. Introduction and Purpose

1.1 Our Commitment

Montage (“Montage”, “we”, “us” or “our”) is committed to conducting business with integrity and in accordance with the highest ethical standards. Central to this commitment is creating an environment where individuals feel safe to speak up when they witness conduct that may be wrong, unethical, or contrary to our values.

We believe that a culture of openness and accountability is essential to good governance. When people are empowered to raise concerns without fear of retaliation, problems can be identified and addressed before they escalate, protecting our employees, business partners, and reputation.

1.2 Purpose of This Policy

This Whistleblower Policy (“Policy”) establishes a framework for:

  • Encouraging the reporting of suspected wrongdoing, misconduct, or unethical behaviour
  • Providing clear channels through which concerns can be raised
  • Protecting those who report concerns in good faith from any form of retaliation
  • Ensuring concerns are properly investigated and addressed
  • Safeguarding the rights of individuals who may be the subject of reports

1.3 Scope and Application

This Policy applies to all individuals connected with Montage who wish to report concerns about potential wrongdoing. This includes:

  • Current and former directors, officers, and employees of Montage
  • Contractors, consultants, and temporary personnel engaged by Montage
  • Suppliers, agents, distributors, and their employees
  • Business partners and joint venture participants
  • Family members or dependants of any of the above who become aware of relevant concerns

Throughout this Policy, any person who makes a report under these provisions is referred to as a “Reporter.”

2. What Can Be Reported

2.1 Reportable Conduct

This Policy is designed to address serious concerns about conduct that may harm Montage, its stakeholders, or the public interest. A report may be made where the Reporter has reasonable grounds to believe that wrongdoing has occurred, is occurring, or is likely to occur.

Reportable conduct includes, but is not limited to:

  • Fraud, theft, embezzlement, or misappropriation of assets
  • Bribery, corruption, or improper payments to officials or third parties
  • Money laundering or terrorist financing activities
  • Violations of trade sanctions, export controls, or customs regulations
  • Falsification of financial records, accounts, or business documents
  • Conflicts of interest that have not been properly disclosed or managed
  • Serious breaches of health, safety, or environmental obligations
  • Modern slavery, human trafficking, or forced labour in our supply chain
  • Conduct that poses a substantial risk to public health, safety, or the environment
  • Deliberate concealment of any of the above
  • Any other serious breach of law, regulation, or Montage policies

2.2 What This Policy Does Not Cover

This Policy is intended for matters of significant concern that affect Montage as an organisation or the public interest. It is not designed to address personal workplace grievances or routine employment matters.

The following matters should generally be raised through other channels:

  • Personal disputes with colleagues or managers
  • Disagreements about performance assessments or compensation
  • Routine human resources matters such as leave requests or benefits
  • Minor policy violations that do not indicate systemic issues

However, if a personal grievance also reveals broader misconduct—such as a pattern of discriminatory behaviour by management or systemic non-compliance with policies—it may be appropriately reported under this Policy.

2.3 Requirement for Good Faith

Reports made under this Policy must be made in good faith, meaning the Reporter genuinely believes that wrongdoing has occurred based on reasonable grounds. The Reporter does not need to have definitive proof—a reasonable belief based on available information is sufficient.

However, knowingly making a false, malicious, or vexatious report is a serious matter that may itself constitute misconduct and could result in disciplinary action.

3. How to Report a Concern

3.1 Internal Reporting Channels

Montage encourages Reporters to raise concerns internally in the first instance, as this typically allows for the most effective and timely response. Several internal channels are available:

Designated Compliance Officer

The primary channel for whistleblower reports is our Compliance Officer, who has been specifically designated to receive and handle such matters. Reports may be submitted by email to [email protected] or in writing marked “Confidential – Whistleblower Report” to the address below.

Senior Management

Alternatively, reports may be made directly to the Chief Executive Officer or any member of senior management. This may be appropriate where the Reporter has an existing relationship of trust with a particular manager or where the nature of the concern makes this channel more suitable.

External Legal Counsel

Where a Reporter prefers to raise a concern through an external party, or where the concern relates to senior management, reports may be made to Montage’s external legal counsel. Contact details are available from the Compliance Officer upon request.

3.2 Anonymous Reporting

Montage accepts anonymous reports. While providing identity information often assists in the investigation process, we recognise that some individuals may not feel comfortable doing so. Anonymous reports will be assessed and investigated to the extent possible based on the information provided.

Reporters who wish to remain anonymous should be aware that this may limit our ability to investigate thoroughly, seek clarification, or provide feedback on the outcome. We encourage anonymous Reporters to provide a secure means of follow-up contact if possible, such as a non-work email address.

3.3 External Reporting

In certain circumstances, it may be appropriate to report concerns to external authorities. This includes situations where internal reporting has not resulted in appropriate action, where the matter involves senior leadership, or where there is an imminent risk of serious harm.

Relevant external authorities may include:

  • Dubai Multi Commodities Centre (DMCC) regulatory authorities
  • UAE Central Bank (for financial crime matters)
  • Dubai Police or UAE Public Prosecution (for criminal matters)
  • Other competent regulatory authorities in jurisdictions where Montage operates

Reporters considering external disclosure are encouraged to seek independent legal advice to understand their rights and any applicable protections.

3.4 Contact Information

Reports may be submitted to:

Compliance Officer

Montage

Office No. 1302, Saba 1

Jumeirah Lake Towers, Cluster E

Dubai, United Arab Emirates

Email: [email protected]

4. Protection of Reporters

4.1 Prohibition of Retaliation

Montage strictly prohibits any form of retaliation against individuals who make reports under this Policy in good faith. This protection applies regardless of whether the concerns raised are ultimately substantiated.

Retaliation includes, but is not limited to:

  • Dismissal, demotion, or adverse changes to employment terms
  • Harassment, bullying, or intimidation
  • Discrimination in any aspect of employment
  • Threats or other coercive conduct
  • Exclusion from meetings, projects, or opportunities
  • Damage to reputation or professional standing
  • Any other conduct that constitutes a detriment to the Reporter

Any employee who engages in retaliatory conduct will be subject to disciplinary action, which may include termination of employment. Montage will also take appropriate action against contractors, suppliers, or other third parties who engage in retaliation.

4.2 Confidentiality

Montage will treat all whistleblower reports with strict confidentiality. The identity of the Reporter will not be disclosed without their consent, except where disclosure is required by law or is necessary to enable effective investigation (and then only to the minimum extent necessary).

Where it becomes necessary to disclose information that may identify the Reporter, we will inform the Reporter in advance where practicable, unless doing so would prejudice the investigation or is prohibited by law.

All personnel involved in receiving, handling, or investigating whistleblower reports are required to maintain confidentiality and may face disciplinary action for unauthorised disclosure.

4.3 Secure Record Keeping

All records relating to whistleblower reports will be stored securely with access restricted to authorised personnel only. Documentation will be maintained in accordance with applicable data protection requirements and our internal record retention policies.

4.4 Support for Reporters

Montage recognises that raising concerns about wrongdoing can be stressful. Reporters who are employees may access support through our employee wellbeing resources. Reporters may also seek independent legal advice at any time regarding their rights and options.

5. Investigation Process

5.1 Initial Assessment

Upon receipt of a report, the Compliance Officer (or designated recipient) will conduct an initial assessment to determine whether the matter falls within the scope of this Policy and warrants investigation. This assessment will normally be completed within ten (10) working days of receipt.

If the matter does not fall within the scope of this Policy, the Reporter will be informed (where contact details have been provided) and, where appropriate, directed to alternative channels for addressing their concern.

5.2 Conducting the Investigation

Where an investigation is warranted, Montage will appoint an appropriate investigator. Depending on the nature and seriousness of the allegations, this may be an internal manager with no connection to the matter, the Compliance Officer, or an external investigator.

The investigation will typically involve:

  • Gathering and reviewing relevant documents and records
  • Interviewing the Reporter (if they have consented to be contacted)
  • Interviewing witnesses and other relevant individuals
  • Providing any person against whom allegations are made an opportunity to respond
  • Preparing a written report with findings and recommendations

5.3 Timeframes

Montage aims to complete investigations within sixty (60) days of determining that an investigation is warranted. Complex matters may require additional time. Where investigations cannot be completed within this timeframe, the Compliance Officer will ensure that reasonable progress is being made and will keep the Reporter informed (if their identity is known).

5.4 Outcomes and Follow-Up

At the conclusion of an investigation, findings will be reported to the Chief Executive Officer or, where appropriate, to the Board of Directors. Depending on the findings, outcomes may include disciplinary action against individuals, referral to law enforcement authorities, changes to policies or procedures, or other remedial measures.

The Reporter will be informed of the outcome of their report to the extent appropriate and consistent with privacy and confidentiality obligations. This will typically confirm whether the investigation has been completed and whether action has been taken, without disclosing specific details about any disciplinary outcomes affecting other individuals.

6. Fair Treatment of Persons Subject to Reports

6.1 Presumption of Innocence

Individuals who are the subject of a whistleblower report are entitled to fair treatment. Being the subject of a report does not imply guilt or wrongdoing. All persons are presumed innocent until an investigation has been completed and findings have been made.

6.2 Confidentiality

The identity of individuals who are the subject of a report will be kept confidential to the extent practicable during the investigation. Information will only be shared with those who have a legitimate need to know for the purposes of the investigation.

6.3 Right to Respond

Before any adverse findings are made, individuals who are the subject of a report will be informed of the substance of the allegations against them (to the extent this can be done without compromising the investigation or the Reporter’s identity) and will be given a reasonable opportunity to respond.

6.4 Support

Individuals who are the subject of a report may also access support through employee wellbeing resources and may seek independent legal advice regarding their rights.

7. Policy Governance

7.1 Ownership and Review

This Policy is owned by the Compliance Officer and approved by the Chief Executive Officer. It will be reviewed at least annually to ensure it remains effective and reflects current best practices and legal requirements.

7.2 Training and Awareness

Montage will ensure that all employees and relevant stakeholders are made aware of this Policy and understand how to raise concerns. Training will be provided to personnel responsible for receiving and handling whistleblower reports.

7.3 Related Policies

This Policy should be read in conjunction with:

  • Code of Conduct
  • Anti-Bribery and Corruption Policy
  • Supplier Code of Conduct
  • Privacy Policy
  • Disciplinary Policy

7.4 Amendments

Montage reserves the right to amend this Policy at any time. The current version will be made available to all employees and, upon request, to other relevant stakeholders.

Document Information

Version: 1.0

Effective Date: November 2025

Policy Owner: Compliance Officer

Approved By: Chief Executive Officer

Review Cycle: Annual