§ 08 — Governance
Whistleblower Policy
Wepex Group is committed to the highest standards of integrity, transparency, and accountability. This policy ensures that any individual can report suspected wrongdoing without fear of retaliation.
Wepex Group operates across 26 countries and employs 38,000 people. At this scale, the early detection of fraud, corruption, safety violations, and regulatory breaches is not merely desirable — it is essential to the trust our clients, shareholders, and communities place in us. Our whistleblower programme exists to ensure that every employee, contractor, supplier, and member of the public can raise concerns through channels that are confidential, secure, and free from retaliation.
This policy applies to all Wepex Group entities worldwide and covers reports of actual or suspected: fraud or financial misstatement; bribery and corruption; violations of competition law; serious safety incidents or near-misses that have been concealed; environmental damage or regulatory non-compliance; harassment, discrimination, or human rights violations; and any other conduct that could cause serious harm to Wepex Group, its people, or the communities in which it operates.
Reports may be made anonymously where local law permits. Wepex Group will not tolerate retaliation of any kind against individuals who make reports in good faith, regardless of whether the investigation confirms the concern. This protection extends to employees, contractors, agency workers, interns, and job applicants.
Reporting Channels
How to raise a concern
Channel 01
Wepex Ethics Hotline
Available 24 hours a day, 7 days a week, in 15 languages. Operated by an independent third-party provider to ensure confidentiality. Trained intake specialists document your concern and forward it to the Wepex Ethics & Compliance Office within 24 hours.
+1 800 937 8194 (US toll-free)
+44 800 047 8194 (UK toll-free)
+971 800 819 4000 (UAE toll-free)
Channel 02
Online Reporting Portal
Secure, encrypted web portal accessible from any device. You may attach documents, photographs, and other evidence. Reports are assigned a unique tracking number so you can follow up anonymously. The portal supports anonymous two-way communication with investigators.
wepex.ethicspoint.com
Channel 03
Direct Report to Ethics & Compliance
You may report directly to the Chief Ethics & Compliance Officer or the General Counsel. These individuals have a direct reporting line to the Audit Committee of the Board and are empowered to initiate investigations independently of operational management.
ethics@wepexgroup.com
Channel 04
Board Audit Committee
For reports involving senior management (VP level and above), or where the reporter prefers to bypass the Ethics & Compliance Office entirely, concerns may be submitted directly to the Chair of the Audit Committee via the Company Secretary.
audit.committee@wepexgroup.com
Protection
Non-retaliation commitment
Prohibited retaliation
Wepex Group prohibits any form of retaliation — including termination, demotion, suspension, threats, harassment, reduction in hours, reassignment to undesirable duties, or any other adverse action — against any individual who reports a concern in good faith. This prohibition applies regardless of whether the underlying report is substantiated. Managers who retaliate against whistleblowers face disciplinary action up to and including termination.
Confidentiality
The identity of any individual who reports a concern will be treated as confidential to the fullest extent possible under applicable law. Access to whistleblower identities is restricted to the Ethics & Compliance Office, the General Counsel, and the Audit Committee. In no case will a reporter's identity be disclosed to the subject of the report without their prior consent, unless required by law or to facilitate an investigation.
Investigation process
All reports are acknowledged within 5 business days. Investigations are assigned within 10 business days. The Ethics & Compliance Office provides status updates to the reporter at 30-day intervals where possible. Investigations are conducted by qualified internal investigators or, where independence demands it, by external counsel. At the conclusion of an investigation, the reporter is informed of the outcome in general terms, subject to privacy and legal constraints.
Legal protections
Wepex Group's whistleblower programme is designed to comply with and exceed the requirements of: the EU Whistleblower Directive (Directive (EU) 2019/1937); the UK Public Interest Disclosure Act 1998; the US Dodd-Frank Act, Section 922; the UAE Federal Decree-Law No. 34/2023 on combating fraud and corruption; and applicable whistleblower protection laws in every jurisdiction where Wepex Group operates.
Scope
What you can report
Financial misconduct
Fraud, embezzlement, false financial reporting, misrepresentation of project costs, bid-rigging, or price-fixing.
Corruption & bribery
Offering, promising, or accepting bribes or kickbacks; improper facilitation payments; conflicts of interest involving public officials; violations of the US Foreign Corrupt Practices Act or UK Bribery Act.
Safety & environment
Concealment of serious safety incidents or near-misses; falsification of safety records; environmental damage; unpermitted discharge of pollutants; failure to report regulated substances.
Human rights
Forced labour, child labour, or human trafficking in Wepex operations or supply chains; workplace harassment or discrimination; retaliation against those raising concerns.
Regulatory breach
Violations of competition law; sanctions evasion; export control violations; data protection breaches; failure to obtain required permits or licences.
Other wrongdoing
Theft of company assets; misuse of insider information; obstruction of audits or investigations; any conduct that could cause serious harm to Wepex, its people, or the public.
Contact
Ethics & Compliance Office
The Wepex Group Ethics & Compliance Office is staffed by a team of 14 investigators and compliance professionals based in New York, London, Dubai, and Singapore. The office reports directly to the Chief Ethics & Compliance Officer, who in turn reports to the Audit Committee of the Board — not to operational management — to ensure independence.
Mailing address
Ethics & Compliance Office
Wepex Group Inc.
200 Park Avenue, 42nd Floor
New York, NY 10166
United States
Direct contact
Email: ethics@wepexgroup.com
Hotline: +1 800 937 8194
Portal: wepex.ethicspoint.com
Encrypted: Signal +1 212 555 0142
This policy is reviewed annually by the Audit Committee and updated as required. The current version was approved on 1 January 2026. Previous versions are available upon request from the Company Secretary. If you are unsure whether this policy applies to your situation, please contact the Ethics & Compliance Office for confidential guidance.