Whistleblower Policy

Arcangel Protection Services (Pty) Ltd.

Effective Date: 2026/06/03
Last Update: 2026/06/03

1. Purpose

Arcangel Protection Services (Pty) Ltd ("Arcangel") is committed to maintaining the highest standards of integrity, professionalism, accountability, and ethical conduct.

The purpose of this Whistleblower Policy is to encourage the reporting of misconduct, unlawful conduct, unethical behaviour, safety concerns, and other improper activities that may affect Arcangel, its employees, clients, suppliers, contractors, or stakeholders.

This Policy establishes a framework for reporting concerns in good faith and provides protections against retaliation for individuals who make protected disclosures.

2. Our Commitment

Arcangel is committed to:

• Promoting ethical conduct;

• Maintaining transparency and accountability;

• Encouraging the reporting of genuine concerns;

• Protecting whistleblowers acting in good faith;

• Investigating reports appropriately and objectively;

• Taking corrective action where necessary;

• Complying with applicable laws and regulatory obligations.

Arcangel recognises that individuals are often the first to become aware of misconduct and play an important role in identifying and preventing harm.

3. Who May Report

Reports may be made by:

• Employees;

• Contractors;

• Consultants;

• Suppliers;

• Service providers;

• Business partners;

• Applicants;

• Former employees;

• Clients;

• Members of the public.

This Policy applies regardless of employment status or contractual relationship.

4. Reportable Concerns

Concerns that may be reported include, but are not limited to:

Fraud

• Financial fraud

• Procurement fraud

• Misappropriation of assets

• False claims

Corruption and Bribery

• Bribery

• Kickbacks

• Improper inducements

• Abuse of authority

Criminal Conduct

• Theft

• Fraudulent activity

• Unlawful conduct

• Regulatory violations

Workplace Misconduct

• Harassment

• Bullying

• Discrimination

• Abuse of authority

• Unethical conduct

Health and Safety Concerns

• Unsafe working conditions

• Serious safety breaches

• Failure to comply with safety requirements

Human Rights Concerns

• Human trafficking

• Forced labour

• Child labour

• Exploitation

• Modern slavery

Information Security and Privacy

• Data breaches

• Unauthorised access to information

• Misuse of confidential information

• Privacy violations

• Cybersecurity concerns

Regulatory and Compliance Violations

• Violations of applicable laws

• Breaches of company policies

• Serious ethical concerns

• Professional misconduct

5. Good Faith Reporting

Reports should be made honestly and in good faith.

A whistleblower is not required to prove wrongdoing before making a report.

However, individuals should have reasonable grounds to believe that the information being reported may indicate misconduct or wrongdoing.

Good faith reports will be treated seriously, even if investigations ultimately determine that no wrongdoing occurred.

6. Confidentiality

Arcangel will make reasonable efforts to maintain the confidentiality of whistleblowers and reported information.

Information will only be disclosed where:

• Necessary to conduct an investigation;

• Required by law;

• Required by regulatory authorities;

• Necessary to protect the rights of affected persons.

Absolute confidentiality cannot be guaranteed in all circumstances, particularly where legal obligations require disclosure.

7. Anonymous Reporting

Individuals may submit reports anonymously where permitted by law.

Anonymous reports will be assessed and investigated to the extent reasonably possible.

The ability to investigate anonymous reports may be limited where insufficient information is provided.

8. Protection Against Retaliation

Arcangel strictly prohibits retaliation against any individual who makes a report in good faith.

Prohibited retaliation may include:

• Dismissal

• Demotion

• Harassment

• Intimidation

• Victimisation

• Threats

• Discrimination

• Unfair treatment

Any person found to have engaged in retaliation may be subject to disciplinary action and, where appropriate, legal action.

9. False or Malicious Reports

Arcangel encourages responsible use of this Policy.

Reports that are knowingly false, intentionally misleading, malicious, or made in bad faith may result in disciplinary action or other appropriate measures.

This provision does not apply to good faith reports that are ultimately unsubstantiated.

10. Investigation Process

Upon receiving a report, Arcangel may:

• Acknowledge receipt where possible;

• Conduct a preliminary assessment;

• Gather relevant information;

• Assign appropriate personnel or external specialists;

• Conduct investigations where warranted;

• Implement corrective actions where necessary.

The nature and scope of any investigation will depend on the circumstances and seriousness of the reported concern.

11. Outcomes

Where investigations substantiate misconduct, Arcangel may take appropriate action, including:

• Corrective measures;

• Disciplinary action;

• Contractual remedies;

• Process improvements;

• Regulatory reporting;

• Referral to law enforcement authorities.

12. Legal Framework

This Policy should be read together with applicable legislation, including:

South Africa

• Protected Disclosures Act, 2000

• Labour Relations Act, 1995

• Prevention and Combating of Corrupt Activities Act, 2004

• Protection of Personal Information Act, 2013

Where applicable, Arcangel will seek to comply with relevant legal obligations relating to whistleblower protection and disclosure management.

13. CONTACT DETAILS

General Reporting

Email: hello@arcangel.co.za

Compliance and Governance Reporting

Email: privacy@arcangel.co.za

Written Correspondence

Arcangel Protection Services (Pty) Ltd

Reports should include sufficient information to enable an assessment and, where appropriate, an investigation.

Relevant information may include:

• Nature of the concern;

• Individuals involved;

• Dates and locations;

• Supporting evidence;

• Any immediate risks.

14. Responsibilities

All personnel are expected to:

• Act ethically;

• Report genuine concerns;

• Cooperate with investigations;

• Respect confidentiality;

• Avoid retaliation.

Management is responsible for promoting awareness of this Policy and ensuring concerns are handled appropriately.

15. Policy Review

Arcangel may review and update this Policy periodically to reflect legal developments, operational requirements, and best practices.

Updated versions will be published where appropriate.