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Reporting Ethical Misconduct

• Caelum operates an ethics violation reporting system to foster an ethical and transparent corporate culture.

• Any stakeholder of Caelum may file a report if they become aware of any corruption, misconduct, or violations of laws or ethical standards committed by Caelum employees.

Scope of Reporting

• Requesting or accepting money, gifts, entertainment, or personal favors beyond customary levels in connection with duties.

• Illegal acts that cause loss or damage to the Company or stakeholders, such as embezzlement, breach of trust, fraud, forgery of documents, or misappropriation of company assets.

• Solicitations or mediation that interfere with fair business operations for personal gain or for the benefit of a third party.

• Acts that cause significant loss or disrupt business operations due to intentional misconduct or gross negligence.

• Any other unethical or illegal acts violating laws, internal regulations, or the Code of Ethics.

Whistleblower Protection

• Caelum guarantees the confidentiality of whistleblowers and protects them from experiencing any disadvantages as a result of reporting.

• Personal details and any information that could identify the reporter are strictly protected.

• Identity will not be disclosed without the reporter's consent.

• Unfair retaliatory measures or disadvantages due to reporting are strictly prohibited.

• If a reporter experiences any disadvantage, the Company will implement necessary protective measures.

Filing a Report

• Reports may be submitted either under a real name or anonymously.

• Real-name reporting is recommended to ensure a faster and more accurate fact-checking process.

• Please provide detailed information using the 5W's and 1H framework (Who, What, When, Where, Why, and How).

• Submitting relevant supporting documents allows for a more rapid investigation.

• Reports based on false allegations, ungrounded slander, or malicious intent may be excluded from investigation.

Contact Information

• Email for Reports: compliance@caelumglobal.com