Stormtech Canada Associate Handbook

WHISTLEBLOWING POLICY

1. PURPOSE Stormtech is committed to maintaining the highest standards of integrity, transparency, and ethical conduct across all areas of its operations. This policy provides Associates with a secure and confidential channel for reporting concerns related to unethical behavior, misconduct, or potential legal and/or regulatory violations, without fear of retaliation. The goal is to encourage a culture of openness, accountability, and trust within the organization. This policy also supports Stormtech’s compliance with applicable laws and internal standards.

2. SCOPE

This policy applies to all Stormtech Associates (employees). While Stormtech encourages ethical behaviour among partners and suppliers, formal reporting procedures outlined herein are intended solely for internal use. Note: This policy does not create reporting obligations or rights for subcontractors, vendors, or third parties, nor does it establish a formal grievance mechanism for external entities

3. POLICY

Stormtech encourages all Associates to report any concerns made in good faith. “Good faith” means the reporter genuinely believes the concern to be true, even if it is later found to be unsubstantiated. Reportable concerns may include, but are not limited to: • Bribery or corruption • Conflicts of interest • Fraudulent activity or financial misrepresentation • Money laundering • Misuse of company assets or confidential information • Violations of the Code of Ethics or other company policies • Any other activity that is unethical, unlawful, or violates internal controls Indicators may include:

• Offering or accepting unauthorized cash, gifts, or kickbacks • Concealing personal interests when making business decisions • Altering or misreporting financial documents or expenses • Routing payments through third parties to hide improper activities

4. REPORTING PROCESS

Concerns can be reported through the following confidential channels: • Email: confidentialconcerns@stormtech.ca (monitored by the Compliance Officer) • Physical Form: Accessible via Confluence or the People & Culture department

Stormtech will treat all reports with strict confidentiality and will protect the identity of the reporter to the fullest extent possible, subject to legal obligations. Reporters are encouraged to include sufficient detail (e.g., names, dates, relevant documents) to support effective investigation. Where permitted by law, anonymous reports are allowed and will be treated with the same level of seriousness.

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