Whistleblower & Speak-Up Policy

Introduction

PMG Consulting (hereafter referred to as PMG) is committed to maintaining the highest standards of ethical conduct, legal compliance, and organizational integrity across all its operations and engagements. This policy establishes a safe, confidential, and structured mechanism through which concerns about misconduct, ethical violations, legal breaches, or policy violations may be raised without fear of retaliation. PMG expects all those who interact with the organization to act with integrity and to speak up when they become aware of conduct that falls short of that standard.

Scope

This policy applies to all PMG personnel as defined in L-907, including employees, contractors, consultants, and all other persons whose work affiliation is with PMG, whether compensated or not. It additionally applies to clients, third parties, and suppliers who become aware of conduct within PMG's operations that falls within the categories described in this policy. All such persons are referred to herein as "reporters."

Definitions

Term	Definition
Reporter:	Any individual who submits a report under this policy, whether identified or anonymous.
Ethics Officer:	The designated PMG officer responsible for receiving, managing, and investigating reports made under this policy.
Retaliation:	Any adverse action taken, or threatened to be taken, against a reporter as a result of or in connection with a report made in good faith under this policy. This includes but is not limited to termination, demotion, exclusion, harassment, contract non-renewal, or any other punitive measure.
Good Faith Report:	A report made on the basis of a genuine, reasonable belief that the conduct described has occurred, is occurring, or is likely to occur. The standard for good faith is objective: a report is made in good faith where a reasonable person, acting with the knowledge available to them at the time of the report, would believe the concern was warranted. A report is not made in bad faith solely because it is unsubstantiated following investigation, or because the reporter was mistaken about facts that were not reasonably available to them at the time.
Substantiated Report:	A report in respect of which investigation has produced sufficient evidence to conclude that the reported conduct occurred or is occurring.

1. Covered Conduct

1.1 This policy covers reports concerning any of the following categories of conduct:

• Misconduct or ethical violations, including dishonesty, fraud, misrepresentation, abuse of authority, or conduct contrary to PMG's stated values;
• Legal or regulatory breaches, including violations of applicable law, regulatory requirements, or obligations owed to clients, counterparties, or public authorities;
• Policy violations, including misuse of PMG intellectual property as defined in L-907, conflicts of interest as defined in L-902, breaches of information security obligations as defined in L-906, violations of PMG's Anti-Bribery & Corruption Policy (L-916), Modern Slavery & Human Rights Policy (L-908), or any other PMG policy.

1.2 This policy is intended for reports concerning conduct within PMG's operations, personnel, or engagements. It does not govern commercial disputes, contractual disagreements, or matters addressed by other PMG policies that provide their own dispute resolution mechanisms, except where such matters also involve the categories of conduct described in section 1.1.

2. The Ethics Officer

2.1 PMG designates an Ethics Officer as the primary recipient and manager of all reports made under this policy. The Ethics Officer may be contacted at:

Attn: Ethics Officer
PMG Consulting
ethics@askPMG.com

2.2 Where a report concerns the conduct of the Ethics Officer personally, or where the reporter has a reasonable basis to believe the Ethics Officer may have a conflict of interest in respect of the reported matter, the report shall instead be submitted to:

Attn: Legal
PMG Consulting
legal@askPMG.com

2.3 Where a report concerns the conduct of PMG's legal function broadly, or where the reporter has a reasonable basis to believe that the legal team may be implicated in or conflicted with respect to the reported matter, the report shall instead be submitted to:

headsup@askPMG.com

This inbox is accessible exclusively to PMG's executive leadership. Reporters should be aware that this constitutes a defined group of senior individuals within PMG. Where a reporter's concern involves one or more members of PMG's executive leadership specifically, the reporter is encouraged to identify this in their submission so that the remaining recipients may manage the matter with appropriate recusal of the implicated individual or individuals.

2.4 PMG shall ensure that all three reporting channels described in this section are maintained, monitored, and accessible at all times. The existence and contact details of each channel shall be communicated to all PMG personnel upon onboarding and shall be made available on request to clients, contractors, and third parties.

3. Making a Report

3.1 Reports may be submitted in writing to the applicable contact identified in Section 2. Reports should include, to the extent possible, a description of the conduct of concern, the identity of any individuals involved, the approximate date or period during which the conduct occurred or is occurring, and any supporting information or documentation available to the reporter.

3.2 Reports may be submitted anonymously. PMG will accept and consider anonymous reports. However, anonymous reports may, by their nature, limit the Ethics Officer's ability to seek clarification, provide updates, or conduct a fully informed investigation. Accordingly, anonymous reports will be assessed and investigated to the extent reasonably practicable given the information provided, but may be accorded less weight in the investigative process where the absence of identifying information prevents adequate corroboration or follow-up. This limitation does not affect PMG's obligation to take all reports seriously and to investigate where sufficient information exists to do so.

3.3 A report submitted under this policy must be made in good faith, as defined above. PMG reserves the right to take appropriate disciplinary or legal action against any person who knowingly submits a false, malicious, or bad faith report intended to harm another individual or to abuse the reporting mechanism. For the avoidance of doubt, a reporter who acts in good faith but is mistaken in their belief is not subject to any adverse consequence under this section. See the definition of Good Faith Report above.

4. Confidentiality

4.1 PMG treats the identity of all reporters as strictly confidential. PMG's commitment to confidentiality is absolute with respect to any voluntary disclosure. PMG will not, under any circumstances and of its own volition, disclose the identity of a reporter to any person within or outside PMG, except with the express prior written consent of the reporter.
4.2 PMG acknowledges that certain legal processes, regulatory obligations, or binding court orders may compel disclosure of a reporter's identity regardless of PMG's wishes. Such compelled disclosure does not represent a breach of this policy. Where PMG is subject to or anticipates such a compelled disclosure obligation, PMG shall take all reasonable and available legal steps to resist or limit that disclosure, shall notify the reporter to the extent permitted by applicable law, and shall treat any disclosure that ultimately occurs as strictly limited to what is legally required. PMG makes no representation as to the extent of legal steps it will take to resist compelled disclosure, and reporters who have concerns about the risk of compelled disclosure in their specific circumstances are encouraged to seek independent legal advice.
4.3 All information contained in a report, including the substance of the concern and any supporting documentation, shall be handled on a strictly need-to-know basis. Access shall be limited to the Ethics Officer and any persons the Ethics Officer determines are necessary for the conduct of the investigation, each of whom shall be bound by the same confidentiality obligations set out in this section.

5. Investigation

5.1 Upon receipt of a report, the Ethics Officer shall issue a written acknowledgement of receipt to the reporter within five (5) business days. Where a report is submitted anonymously and no contact channel has been provided, this acknowledgement obligation does not apply. Following acknowledgement, the Ethics Officer shall assess the report and determine the appropriate course of action. The Ethics Officer has full discretion to determine the scope, method, and timeline of any investigation, and to determine whether a report contains sufficient information to proceed.
5.2 The Ethics Officer may, at their discretion, engage PMG executive leadership or external legal counsel to assist in or conduct the investigation where the complexity, seriousness, or subject matter of the report warrants it. Where external counsel is engaged, such counsel shall be bound by the same confidentiality obligations applicable to the Ethics Officer under Section 4.

Where a report is substantiated, the Ethics Officer shall refer the matter for action in accordance with the following escalation ladder:

1. Where the reported conduct involves non-leadership PMG personnel, the Ethics Officer shall refer the matter to the relevant department head for appropriate action;
2. Where the reported conduct involves senior leadership or C-suite personnel, the Ethics Officer shall refer the matter directly to PMG's Board of Directors or, where the Board is implicated or unavailable, to an independent external auditor appointed by the Ethics Officer;
3. Where the reported conduct involves the Ethics Officer personally, the matter shall be referred directly to PMG's executives via the headsup@askPMG.com channel described in Section 2.3;
4. In all cases, the Ethics Officer shall use their judgment to ensure that the referral is made to a person or body that has no material conflict of interest with respect to the subject matter of the report. Where no unconflicted internal recipient exists, the matter shall be referred to external counsel or an independent auditor as a default.

5.3 The subject of a report shall be afforded a reasonable opportunity to respond to the findings of an investigation before any determination is made, except where doing so would compromise the integrity of the investigation or the confidentiality of the reporter.
5.4 Upon conclusion of an investigation, the Ethics Officer shall prepare a written determination setting out the findings and any recommended actions. Where the report is substantiated, the Ethics Officer shall refer the matter to the appropriate PMG leadership or external authority for action. Where the report is not substantiated, the matter shall be closed and a record retained in accordance with L-918.
5.5 A reporter is not entitled to information regarding the outcome or findings of an investigation conducted under this policy, or regarding any disciplinary or remedial action taken as a result. PMG may, at the Ethics Officer's discretion, provide a reporter with limited information regarding the outcome where the nature of the reported conduct is such that the reporter has a direct and material interest in being informed, or where applicable law requires such disclosure. Where a reporter has identified themselves and the Ethics Officer determines that disclosure is appropriate, any information shared shall be limited to what is strictly necessary and shall not include details of disciplinary actions taken against any other individual.

6. Non-Retaliation

6.1 PMG strictly prohibits retaliation of any kind against any person who makes a good faith report under this policy. This prohibition applies to all PMG personnel, regardless of seniority, and to any client, contractor, supplier, or third party acting in connection with a PMG engagement.
6.2 Any PMG personnel found to have engaged in retaliation against a reporter shall be subject to disciplinary action up to and including immediate termination of employment or engagement. Where the retaliating party is a client, contractor, or third party, PMG shall take all available steps under the applicable engagement terms to address the conduct, which may include termination of the engagement or contractual relationship.
6.3 Where retaliation against a reporter is established, the original report made by that reporter shall be treated as validated for the purposes of the investigation, meaning that the act of retaliation shall be considered corroborating evidence of the conduct reported, and the investigation shall proceed on that basis unless other evidence clearly establishes otherwise.
6.4 Any person who believes they have experienced retaliation in connection with a report made under this policy should report the retaliation through the same channels set out in Section 2, or through an alternative channel if the original channel is implicated in the retaliatory conduct.

7. Relationship to Other PMG Policies

7.1 This policy operates alongside and does not replace the dispute resolution and escalation mechanisms set out in other PMG policies. Where a concern involves conduct that is also governed by another PMG policy, the reporter may use either this policy or the applicable mechanism in the other policy, or both. PMG personnel responsible for managing reports under this policy shall coordinate with the relevant policy owners where overlap exists.
7.2 Where a report under this policy involves intellectual property matters governed by L-907, the Ethics Officer shall notify the IP Officer of the existence of the report to the extent consistent with the confidentiality obligations in Section 4, without disclosing the reporter's identity.
7.3 This policy does not create an obligation or entitlement to report concerns externally. All reports under this policy are to be made through the internal channels described in Section 2. Nothing in this policy prevents a reporter from fulfilling any independent legal obligation to report to a regulatory or law enforcement authority, but PMG does not facilitate, encourage, or administer external reporting and takes no position on the circumstances in which external reporting may be appropriate. Reporters seeking guidance on external reporting obligations should consult independent legal counsel.

8. Records

8.1 All reports, investigation records, findings, and outcomes shall be retained by the Ethics Officer in accordance with PMG's Document Retention & Destruction Policy (L-918). Records shall be stored securely and access shall be restricted in accordance with the confidentiality obligations set out in Section 4.

9. Administration

9.1 This policy is administered by the Ethics Officer in consultation with PMG's legal team. Questions regarding the interpretation or application of this policy should be directed to the Ethics Officer at ethics@askPMG.com.
9.2 PMG reserves the right to amend this policy at any time. Material amendments will be communicated to all PMG personnel and made available to clients, contractors, and third parties upon request.