Whistleblowing Policy

Spadel is committed to the highest standards of business ethics and legal compliance. It is therefore of great importance for Spadel to have appropriate procedures in place to enable its employees to report any concerns regarding actual or suspected misconduct in Spadel’s operations in a responsible and effective manner, while ensuring that they are protected from retaliation. This Policy is consistent with the “How to Report a Breach” section of the Spadel Group Code of Conduct.