Whistle-blower Policy

With Effect from Immediate

Approved Board of Directors

Last Amended August 11, 2022

Distribution Restricted to ANSA McAL Employees

1.1 OBJECTIVE

ANSA McAL Limited (AML) including all of its subsidiaries which make up the ANSA McAL Group of Companies (hereinafter referred to as the “Group”) is committed to the highest standards of openness, probity and accountability An important aspect of accountability and transparency is enabling staff and stakeholders an opportunity to voice concerns in a responsible and effective manner. A fundamental term of the employment contract is that an employee will faithfully serve his or her employer and not disclose confidential information about the employer’s affairs. Nevertheless, where an individual discovers information which they believe shows serious malpractice or wrongdoing within the Group then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of line management (except for certain instances where the line manager would be the appropriate person to be told).

The Whistleblower Protection Bill, 2022 of Trinidad and Tobago, and the analogous legislation in the Group’s other territories of operation, gives legal protection to employees against being dismissed or penalised by their employers as a result of disclosing serious concerns. The Company has endorsed the provisions set out below to ensure that no member of staff feels threatened or disadvantaged in this process.

It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by ANSA McAL Group of Companies nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or other procedures.

1.2 SCOPE OF POLICY

This policy is designed to guide employees and other stakeholders of ANSA McAL Group of Companies on the use of the whistle-blower channels on raising concerns internally, at a high level and in disclosing information which the individual believes show malpractice or impropriety. This policy is intended to cover concerns for which an initial independent investigation will be conducted, and which may or may not lead to the invocation of other procedures e.g. disciplinary. These concerns could include:

• Financial malpractice or impropriety or fraud

• Failure to comply with a legal obligation or statutes

• Dangers to health & safety or the environment

• Criminal activity

• Improper conduct or unethical behaviour

• Attempts to conceal any of these

1.3 SAFEGUARDS Protection

This policy is designed to offer protection to those employees of the ANSA McAL Group of Companies who disclose concerns outlined in 1.2 above, provided the disclosure is made:

• in good faith;

• in the reasonable belief of the individual making the disclosure;

• that it tends to show malpractice or impropriety; and

• if they make the disclosure to an appropriate person.

It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure.

Confidentiality

ANSA McAL Group of Companies will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the allegation will be kept confidential so long as it does not hinder or frustrate any investigation. In the event that it becomes necessary during the investigation process to reveal the source of the information, this will be done in consultation with the individual making the disclosure. In such an instance, the individual may be required to provide a statement as part of the evidence required.

Anonymous Allegations

All disclosures, even if anonymous, are welcomed, and the Company is committed to investigating any reports made in accordance with this Policy. However, we encourage individuals to put their name to any disclosures they make. The Company will consider the following factors in investigating all allegations:

• The seriousness of the issues raised

• The credibility of the concern

• The likelihood of confirming the allegation from attributable sources

Untrue Allegations

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious and/or false allegations, and particularly if he or she persists with making them, disciplinary/ legal action may be taken against that individual.

1.4 PROCEDURES FOR MAKING A DISCLOSURE

If an employee suspects illegal conduct or conduct involving misuse of ANSA McAL Group of Companies’ assets or in violation of the law, he or she may report it, anonymously if the employee

wishes, and will be protected against any form of harassment, intimidation, discrimination, or retaliation for making such a report in good faith.

Employees can make a report to any of the following ANSA McAL Group of Companies’ executives at any time: Chief Executive Officer, Chief Legal and External Affairs Officer, or the Head, Group Internal Audit via ANSA McAL Group of Companies’ independent third-party secure Hotline or Online Portal:

• The online portal: Link is available at www.ansamcal.com

• The third-party phone service: Toll free numbers available for all operating countries.

1.5 INVESTIGATIVE PROCESS

Group Internal Audit will notify the sender and acknowledge receipt of the reported violation or suspected violation within five (5) business days. All reports will be promptly investigated in a manner intended to protect confidentiality, consistent with a full and fair investigation, and appropriate corrective action will be taken if warranted by the investigation. A summary of the incidents reported and completed investigation report will be presented to the Board of Directors and the relevant Audit Committee.

1.8 APPROVAL

Approved by the Parent Board on ANSA McAL Limited on: August 11, 2022