Empowering Everyone to Speak Up

Why This Policy Matters

At CWB, integrity is the foundation of how we operate. We believe that raising concerns about wrongdoing helps protect our people, our clients, and our reputation.

This policy enables anyone — whether inside or outside our organisation — to safely report unethical or unlawful conduct, without fear of retaliation.

We are committed to maintaining a transparent and responsible culture where every concern is taken seriously and handled confidentially.

What is Whistleblowing?

Whistleblowing means reporting a concern about potential wrongdoing that affects others, the firm, or the public interest. This includes things like:

• Fraud, theft, or embezzlement
• Bribery, corruption, or conflicts of interest
• Financial crime, money laundering, or sanction breaches
• Unsafe practices or serious health and safety risks
• Data protection or privacy violations
• Legal or regulatory breaches
• Harassment, discrimination, or unethical behaviour
• Attempts to cover up any of the above

Reports under this policy are not for individual employment grievances (which are covered by our Grievance Policy).

Who Can Raise a Concern?

Anyone connected to CWB can report a concern. This includes:

• Employees and former employees
• Contractors, interns, and consultants
• Clients, vendors and service providers
• Business partners or affiliates
• Members of the public who have encountered CWB operations or services

How to Raise a Concern

You can submit your concern through any of the following channels:

1. Secure Online Form – Submit directly through our confidential Whistleblowing Form available on this website. You may choose to remain anonymous.
2. Email – Send details of your concern to the Group Compliance Office at compliance@cwbip.com.
3. By Post:
   Group Compliance Office
   CWB Group Holdings Ltd
   ADGM Square, Abu Dhabi Global Market
   Abu Dhabi, United Arab Emirates

We encourage you to provide as much detail as possible so that your concern can be properly reviewed. Anonymous submissions will be accepted and treated seriously.

What Happens Next?

Once your concern is received, here is what you can expect:

• The Group Compliance Office will assess the issue and decide whether a formal investigation is required.
• If an investigation proceeds, it will be handled objectively, confidentially, and by appropriate personnel.
• You may be contacted for further information if contact details are provided.
• We will update you, where possible, once the matter has been reviewed or concluded.

Your Protection

CWB strictly prohibits retaliation against anyone who raises a concern in good faith — even if it turns out to be unfounded. This protection extends to all whistleblowers, whether internal or external, and includes protection from:

• Harassment or intimidation
• Unfair treatment or blacklisting
• Loss of business or contractual disadvantage

If you believe you are being treated unfairly because you spoke up, please contact the Group Compliance Office immediately.

Acting in Good Faith

We ask that all concerns be raised honestly and based on reasonable belief. Knowingly making a false or malicious report is not protected by this policy and may be subject to appropriate action.

Confidentiality

All reports are treated with strict confidentiality. Your identity will only be shared when absolutely necessary (for example, if required by law or to conduct a proper investigation), and we will always let you know in advance.

If you choose to remain anonymous, we will respect that choice, although it may limit our ability to follow up or investigate fully.

Final Notes

You do not need proof before speaking up - just a genuine concern is enough. If you are unsure whether your concern qualifies under this policy, please contact the Group Compliance Office for confidential guidance.