Whistleblowing & Speaking Up Policy

Purpose

Wellbeing Places Equip Limited ("WBP Equip") is committed to conducting its business with integrity, transparency, and accountability.

This Policy sets out the Company's approach to whistleblowing and speaking up, encouraging individuals to raise concerns about wrongdoing, unethical behaviour, or improper practices without fear of retaliation.

Our Commitment

WBP Equip seeks to foster a culture in which:

• concerns can be raised openly and responsibly;
• issues are addressed promptly and fairly; and
• individuals who speak up in good faith are supported and protected.

Raising concerns at an early stage is viewed as a positive and responsible action that helps protect the Company, its stakeholders, and its reputation.

Scope of Concerns

This Policy applies to concerns relating to suspected or actual:

• unlawful or improper conduct;
• fraud, financial crime, or misuse of company resources;
• breaches of governance, compliance, or ethical standards;
• serious misconduct or conflicts of interest;
• risks to data protection, information security, or privacy; or
• deliberate concealment of any of the above.

This Policy is not intended to replace normal operational or performance-management processes, but to provide a route for raising significant concerns in the public interest.

Who Can Raise a Concern

Concerns may be raised by individuals who have a relationship with WBP Equip, including:

• directors and officers;
• employees and contractors;
• advisers and consultants; and
• other parties who become aware of relevant issues through their engagement with the Company.

How to Raise a Concern

WBP Equip encourages concerns to be raised through appropriate governance or reporting channels.

Concerns should be raised honestly, with reasonable belief that the information disclosed is true at the time it is reported.

The Company recognises that concerns may sometimes be sensitive and will treat disclosures with appropriate confidentiality, subject to legal obligations.

Protection Against Retaliation

WBP Equip does not tolerate retaliation against any individual who raises a concern in good faith.

No person should suffer detriment, disadvantage, or adverse treatment as a result of speaking up responsibly.

Malicious or knowingly false allegations, however, may be treated as a serious matter.

Handling of Concerns

Concerns raised under this Policy will be:

• assessed appropriately;
• handled with discretion and fairness; and
• reviewed by individuals with appropriate authority and independence.

Where issues are substantiated, the Company will take proportionate action.

Relationship with Other Policies

This Policy should be read alongside:

• the Governance & Compliance Statement;
• the Anti-Money Laundering & Financial Crime Awareness Statement; and
• the Code of Business Conduct & Ethics.

Together, these documents reflect the Company's commitment to ethical behaviour and responsible governance.

Transparency and Limitations

This Policy provides a high-level overview of the Company's whistleblowing and speaking-up arrangements.

Detailed internal procedures and reporting mechanisms are maintained separately and are not disclosed publicly for confidentiality and security reasons.

Review

This Whistleblowing & Speaking Up Policy is reviewed periodically to ensure it remains appropriate and effective.

All revisions must be approved by the Board and recorded in the Policy Register.