Whistleblowing Policy

The purpose of this policy is to:

• Provide a secure and confidential channel for individuals to report concerns;
• Ensure concerns are handled promptly, professionally, and with strict confidentiality;
• Protect whistleblowers from retaliation or adverse consequences; and
• Foster a culture of accountability and transparency.

This policy applies to:

• Metra clients;
• Employees, contractors, vendors, and other stakeholders engaged with Metra; and
• Any individual who interacts with Metra and has concerns about improper activities.

Whistleblowers are encouraged to report any suspected or actual activities, including but not limited to:

• Fraud, embezzlement, or theft;
• Money laundering or terrorist financing;
• Breaches of AML and CFT regulations;
• Violations of applicable laws, regulations, or regulatory requirements;
• Conflicts of interest or corruption;
• Cybersecurity breaches or misuse of sensitive client data; and
• Any other unethical or illegal activity.

Metra provides the following confidential channel to report concerns:

Whistleblowers are encouraged to provide as much detail as possible to help us investigate effectively, including:

• Description of the suspected activity;
• Date, time, and location of the incident(s);
• Names of individuals involved, if known; and
• Supporting evidence, if available.

Reports can be made anonymously; however, providing contact information may help us follow up with additional questions if needed.

• All reports will be treated with the utmost confidentiality.
• Metra is committed to protecting the identity of whistleblowers unless disclosure is required by law. If disclosure becomes necessary to conduct a proper investigation, we will seek the whistleblower's consent where possible.
• Anonymous reports are accepted and investigated to the extent possible based on the information provided.

Metra strictly prohibits retaliation against individuals who report concerns in good faith. This includes:

• Dismissal or demotion;
• Harassment or discrimination; and
• Any other adverse treatment resulting from whistleblowing.

Any individual found retaliating against a whistleblower will face disciplinary action, up to and including termination of their engagement with Metra.

• Acknowledgement: Upon receiving a report, Metra will acknowledge receipt within 7 business days (if contact information is provided).
• Initial review: The Compliance Department will assess the report to determine its validity and scope.
• Investigation: An investigation will be conducted by the relevant team within 30 days of receipt.
• Resolution: Appropriate actions will be taken based on the findings, and whistleblowers may be informed of the outcome where legally permissible.

Deliberately providing false or misleading information is a serious offence. Metra reserves the right to take appropriate action, including legal measures, against individuals who knowingly submit false reports.

This policy will be reviewed annually by the Compliance Department, or more frequently as required, to ensure compliance with regulatory requirements and alignment with Metra's commitment to integrity and ethical conduct. Any updates will be communicated to all stakeholders.

For inquiries or additional information regarding this policy, please contact Metra Compliance at compliance@metra.ae.