1. Introduction

Manila Group Ltd is committed to maintaining the highest standards of integrity and ethical conduct. This whistleblowing policy is designed to encourage employees, contractors, and stakeholders to report any concerns or suspicions of wrongdoing within the organization.

2. Scope

This policy applies to all employees, contractors, suppliers, and other stakeholders associated with Manila Group Ltd.

3. Reporting Mechanism

a. Internal Reporting

i. Employees are encouraged to report concerns or suspicions of wrongdoing

internally, following the organization’s reporting hierarchy.

ii. Reports can be made to Reden Rubio 07515 411037, who is responsible for

receiving and handling whistleblowing concerns

b. Anonymous

i. The organization recognizes the importance of anonymity for individuals

reporting concerns. An anonymous reporting mechanism, such as a dedicated

hotline or online platform, is provided.

ii. Reports made anonymously will be treated with the same level of attention and seriousness as non-anonymous reports.

c. External Reporting to Authorities

i. In cases where the concern involves potential criminal activity, employees and

stakeholders are encouraged to report the matter directly to law enforcement

authorities, such as the police.

ii. The organization will cooperate fully with any police or regulatory investigations related to such reports.

4. Types of Concerns

Employees are encouraged to report any concerns related to:

a. Financial misconduct or fraud

b. Violations of laws and regulations

c. Ethical breaches

d. Health and safety violations

e. Environmental concerns

 f. Retaliation against whistleblowers

5. Protection Against Retaliation

Manila Group Ltd is committed to protecting whistleblowers from any form of retaliation. Any employee found to be engaging in retaliatory actions will be subject to disciplinary measures, including potential termination.

6. Investigation Process

a. All reported concerns will be promptly and thoroughly investigated.

b. Investigations will be conducted impartially and, where possible, by individuals not directly involved in the matter.

c. Whistleblowers will be kept informed of the progress and outcome of the investigation to the extent permitted by law.

7. Confidentiality

The organization will make every effort to protect the confidentiality of the whistleblower, to the extent permitted by law. However, in certain circumstances, maintaining confidentiality may not be possible.

8. False Reporting

Knowingly making false allegations will not be tolerated and may result in disciplinary action.

9. Communication and Training

Manila Group Ltd will communicate this policy to all employees and stakeholders. Training programs will be implemented to educate employees on the importance of whistleblowing and the procedures for reporting concerns.

10. Review and Updates

This policy will be regularly reviewed to ensure its effectiveness. Updates will be made as necessary to address changes in laws, regulations, or organizational needs.

11. Contacts

For any questions or concerns related to this policy, please contact the office administration team 020 7471 4777.

Joel Ramos

Director

06/01/2025

This Statement is subject to updates and revisions. All employees and stakeholders must regularly review the latest version.