Whistleblower policy

ABiLiTieS Trust B.V. (also ‘ABiLiTieS’), hereafter referred to as ‘The Trust Service Provider’ or ‘TSP’ are committed to conduct business integrity meeting the vision of the TSP. This is amongst others based on regulatory requirements which includes, but is not limited to:

- Act Supervision Trust Offices 2018 (Wet toezicht trustkantoren 2018 ‘Wtt 2018’);
- Wet voorkoming Witwassen en Terrorismefinanciering ‘Wwft’
- Dutch Whistleblower Protection Act (Wet Huis voor Klokkenluiders);
- EU Whistleblower Directive (2019/1937)

This Whistleblower Policy establishes procedures for employees, contractors, suppliers, and other third parties to report suspected misconduct, violations of laws, or unethical behaviour in a confidential and secure manner.

Purpose

The purpose of this policy is to:

• Encourage reporting of concerns about misconduct, including breaches of regulatory requirements, especially those breaches under the Wtt 2018 and Wwft;
• Protect whistleblowers from retaliation in compliance with Dutch Whistleblower Protection Law and the EU Whistleblower Directive;
• Ensure compliance with applicable international and national laws by maintaining a transparent and accountable process for addressing concerns raised by whistleblowers.

Scope

• All employees, managers, directors, and officers of the TSP.
• Contractors, consultants, suppliers, and other third parties who work with or provide services to the TSP.

Types of concerns to report

There are multiple issues which may lead to reporting. In doubt and/or if any concern arises, please consult the Trusted Person and/or the Compliance officer for further advice. Ethical and/or regulatory breaches which harm our organisation should be transparent in order to perform a sound and integer business operations. We therefore encourage reporting in case of any suspected violations, which includes, is not limited to:

Financial Economic Crime and Fraud: Any activities that involve or facilitate Money laundering, Tax integrity, Bribery and Corruption, Sanctions evasion, Fraud and any other financial crime.

Social Unacceptable Behaviour: any activities which are experienced as unacceptable behaviour, internally, in client relationships or experienced during business operations including but not limited to health safety, discrimination, bullying, harassment.

Non-Compliance Wtt 2018: Non-compliance with the regulatory framework for trust offices, such as failing to conduct due diligence, breaches of anti-money laundering (AML) obligations, or insufficient risk management.

Environmental violations: Illicit or socially unacceptable activities and operations that damage the environment. This includes activities of clients and related parties.

Reporting
Reporting a potential issue can be performed multiple secure and confidential reporting channels:

Internal reporting:
- Reporting can be done directly to Management and/or via the Trusted Person, appointed by the Trust Service Provider via the following email address:
info@abilitiestrust.com

- Reporting to a Trusted Person: The TSP appointed a Trusted Person for reporting being J.M. van Loon. In case of doubt the Compliance officer can be consulted as well.

External reporting:
If whistleblowers do not feel comfortable using internal channels, external reporting can be done directly to the following relevant authorities:
- The Dutch Central Bank (‘DNB’): DNB has an anonymous desk for Integrity Reporting. A report, in case of wrongdoing can be submitted online (www.dnb.nl) , by email (meldpuntmisstanden@dnb.nl) or by Post mail:
De Nederlandsche Bank N.V.  | Attn. Integrity Reporting Desk | PO Box 98 |1000 AB Amsterdam
- Dutch Whistleblowing Authorities: in case of wrongdoing which may have a large social impact, reporting can be done with the Dutch Whistleblowing Authorities. See www.huisvoorklokkenluiders.nl for more information (also available in English).

Whistleblowers may choose to report anonymously. Although anonymous reports will be accepted and investigated, individuals are encouraged to provide contact details so that the company can follow up on the report more effectively.

Protection for Whistleblowers

Whistleblowers who report wrongdoing, but reported in faith and integrity, are protected under this policy. In case of requirements are met, there is protection of the Dutch Whistleblower Protection Act who aims to protect Whistleblowers. Protections include but are not limited to:

Non-Retaliation: Retaliation against whistleblowers is strictly prohibited. Any form of dismissal, demotion, harassment, or discrimination because of reporting is unlawful and will result in disciplinary actions against those responsible.

Confidentiality: The identity of the whistleblower will remain confidential unless the whistleblower consents to disclosure, or disclosure is required by law.

Legal Support: TSP will provide legal support and guidance to whistleblowers if they face retaliation or legal actions because of reporting also when this may harm the integrity of the TSP.

Investigation process
After receipt of an Internal report, the following steps will be taken depending how the report is submitted (anonymous, recipient etc):
Confirmation: The whistleblower will receive confirmation of the report within five business days (unless the report is anonymous).

Initial assessment: A preliminary assessment will be conducted by the Compliance Officer, The Trusted Person and/or a designated independent (external) party to determine if the reported issue is serious for further processing.

Investigation: A formal investigation will be initiated within 15 business days of receiving the report. The investigation may involve:

- Interviews with the whistleblower (if known) and relevant parties in case of involvement multiple parties (‘hoor en wederhoor’);
- Collecting evidence and review of documentation, information and other relevant data;
- Consultation with external experts if necessary.

Report response: Once the investigation is completed, the whistleblower (if known) will be informed of the results of the investigation. The specific details of any actions taken may be limited due to confidentiality, but the whistleblower will be assured that the matter has been addressed appropriately.

Follow up: in case of follow-up measures identified, they will be taken depending on the report, topic and parties involved.

Awareness and training

The Trust Service provider promotes a culture of transparency and integrity by:
• Training: Training will be provided to all employees disclosing the rights and obligations under this Whistleblower Policy as well as handling reporting matters;
• Awareness sessions: In case of concerns or matters to be discussed, this will be added to the agenda of the weekly Team meeting;
• Communication: This policy will be made accessible to all employees, contractors, and relevant third parties, both online and on the One Drive of the TSP.