Casacom Whistleblower Protection and Complaints Handling Policy

Casacom is committed to maintaining a professional environment founded on integrity, ethics, and transparency. This policy aims to:

• Encourage employees, partners, clients, and other stakeholders to report any inappropriate conduct or actions that contradict our values.
• Provide a clear and accessible mechanism for handling complaints or grievances, whether internal or external, without fear of retaliation.

This policy applies to all individuals and organizations connected with Casacom, including employees, consultants, suppliers, business partners, clients, community members, and other external stakeholders.

2.1 Covered Issues

Reports may be made regarding the following matters:

• Fraud, corruption, or financial misconduct
• Undisclosed conflicts of interest
• Violations of laws or regulations
• Breach of confidentiality of sensitive information
• Discrimination, harassment, or any form of intimidation
• Misuse of company resources
• Potential or actual negative impacts on the environment or human rights
• Any other conduct that undermines Casacom’s integrity or values
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3.1 For Employees, Suppliers, and Internal Partners

Stakeholders who identify any irregularity may report it confidentially through one of the following means:

• Ethics Officer: Direct report to the person in charge of human resources, a member of the management committee, or an executive.
• Secure email: A dedicated email address (signal@casacom.ca) for confidential reports.
• Anonymous box: An internal mechanism allowing totally anonymous submissions.

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3.2 For the Public and External Stakeholders

Any external person may file a complaint or grievance through our online contact form: https://www.casacom.ca/contact

Messages received through this form are identified, categorized, and processed according to the procedure outlined below.

4.1 Receipt and Acknowledgment

• An acknowledgment of receipt is sent within 5 business days of receiving the complaint

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4.2 Preliminary Assessment

• Verification that the complaint falls within the scope of this policy.
• Assessment of any immediate measures required.

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4.3 Investigation

• Conducted by an independent person or committee.
• Strict respect for confidentiality.
• External third-party involvement may be used to ensure impartiality.

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4.3 Resolution

• A response to the complainant is provided within a target timeframe of 30 business days.
• Clear communication of findings and, where applicable, corrective or disciplinary measures.
• If the complaint is not upheld, a documented explanation of the reasons is provided.

5.1 Casacom's Commitment

No person making a complaint in good faith will face retaliation. Any attempt at intimidation or punitive action will result in disciplinary measures, which may include termination of employment or contract.

5.2 Right of Recourse

In the event of retaliation, the affected person may immediately report the situation through any of the mechanisms described in this policy.

• All reports must be made in good faith.
• Malicious or knowingly false allegations will result in disciplinary measures.

• This mechanism is publicly available on the Casacom website.
• An annual, anonymized review of complaints will be conducted to identify trends and improve our practices.
• This policy will be reviewed periodically to ensure its effectiveness and alignment with best practices