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528 - Whistle Blower Policy

1. Purpose and Commitment

528 Productions is committed to conducting its business with integrity, transparency, and in full compliance with applicable European Union and Belgian legislation.

This Whistleblowing Policy establishes a secure framework enabling individuals to report, in good faith, concerns relating to suspected misconduct, irregularities, or violations of law occurring within or in connection with 528.

The Company promotes a “Speak-Up Culture” where concerns can be raised without fear of retaliation.

2. Legal Framework

This Policy is adopted in accordance with:

· The Law of 28 November 2022 on the protection of persons who report breaches of Union or national law within private legal entities

· Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law

· Applicable Belgian labour law

· The General Data Protection Regulation (EU) 2016/679 (GDPR)

This Policy does not replace statutory complaint mechanisms, labour law rights, or criminal reporting obligations.

3. Scope of Application

3.1 Material Scope

This Policy applies to reports concerning information about breaches, including reasonable suspicions, relating to:

· Violations of EU or Belgian legislation

· Fraud, corruption, bribery or embezzlement

· Financial or tax misconduct

· Anti-competitive practices

· Breaches of labour and employment law

· Discrimination or harassment

· Violations of environmental, health and safety legislation

· Data protection and cybersecurity breaches

· Consumer protection violations

· Breaches of the 528 Code of Ethics

· Serious misconduct affecting the integrity or reputation of the Company

“Information about breaches” includes acts or omissions that have occurred, are ongoing, or are likely to occur.

3.2 Personal Scope

This Policy applies to the following reporting persons:

· Employees (current and former)

· Applicants and candidates

· Self-employed contractors and consultants

· Interns and trainees (paid or unpaid)

· Members of management and directors

· Shareholders

· Suppliers, subcontractors and their personnel

· Any person working under the supervision and direction of contractors

· Any individual who has obtained information in a professional context related to 528

Protection also applies to:

· Facilitators

· Colleagues or relatives of the reporting person who may suffer retaliation

· Legal entities owned or connected to the reporting person

4. Conditions for Protection

A reporting person benefits from legal protection if:

1. The report is made in good faith.

2. The reporting person had reasonable grounds to believe that the information reported was true at the time of reporting.

3. The report falls within the material scope defined above.

4. The reporting procedure defined in this Policy is followed.

Deliberately false reports, malicious accusations or abuse of the system may result in disciplinary action and potential civil or criminal liability.

5. Internal Reporting Channels

528 provides secure internal reporting channels designed to ensure confidentiality.

5.1 Reporting Methods

Reports may be submitted through:

Email: whistleblowing@528.co

Written submission by post (confidential):

528 Productions - Groenbek 32, 8790 Waregem, Belgium

For the attention of: Whistleblowing Officer and Marked: “Strictly Confidential”

Upon request, reports may also be made through a confidential in-person meeting within a reasonable timeframe.

5.2 Designated Responsible Person

Reports are handled by the designated Whistleblowing Officer, appointed by Management.

Where necessary to guarantee independence or avoid conflicts of interest, an external advisor (e.g., external legal counsel or accountant) may be appointed to conduct the investigation.

6. Procedure and Timelines

Upon receipt of a report:

1. Acknowledgment of receipt will be provided within 7 calendar days.

2. The report will be assessed for admissibility and scope.

3. Where required, additional information may be requested.

4. An impartial investigation will be conducted.

5. Feedback will be provided within 3 months from acknowledgment.

Feedback may include:

· Confirmation that the report is being investigated

· Closure of the case

· Corrective or disciplinary measures

· Referral to competent authorities

The reporting person will not receive confidential information that would infringe privacy rights or compromise the investigation.

7. Confidentiality and Data Protection

528 strictly guarantees:

· Confidentiality of the identity of the reporting person

· Confidentiality of any information that could directly or indirectly identify them

· Restricted access to reports on a strict need-to-know basis

Identity disclosure is only permitted:

· With explicit consent of the reporting person; or

· When legally required by judicial or regulatory authorities

7.1 GDPR Compliance

528 acts as Data Controller under GDPR.

Personal data processed under this Policy:

· Is limited to what is strictly necessary

· Is processed solely for handling and investigating reports

· Is protected by appropriate technical and organisational security measures

· Will not be retained longer than necessary

For data protection matters, contact: privacy@528.co

8. Protection Against Retaliation

528 strictly prohibits retaliation against reporting persons.

Retaliation includes, but is not limited to:

· Dismissal or suspension

· Demotion or denial of promotion

· Salary reduction

· Intimidation or harassment

· Discrimination

· Negative performance evaluation

· Reputational damage

· Termination of contracts

· Blacklisting

Any act of retaliation will be treated as serious misconduct and may lead to disciplinary measures.

9. External Reporting

Reporting persons retain the right to submit reports to competent external authorities, including:

Federal Ombudsman

Leuvenseweg 48 bus 6

1000 Brussels

Belgium

Or other competent supervisory or regulatory authorities as provided by law.

10. Internal Responsibilities

· Procurement decisions must consider sustainability criteria where relevant

· Management oversees the implementation of this policy

· Sustainability performance is reviewed periodically using defined KPIs

Employees involved in procurement are expected to understand and apply this policy in their daily activities.

11. Public Disclosure

Public disclosure (e.g., via media) is protected only under the conditions set out in the Law of 28 November 2022, including where:

· No appropriate action was taken following internal or external reporting; or

· There is imminent or manifest danger to the public interest.

12. Record Keeping

528 maintains a secure and confidential register of reports.

Records are retained:

· Only for as long as necessary and proportionate

· In compliance with applicable legal retention obligations

· In accordance with GDPR principles

13. False Reporting

Knowingly reporting false information constitutes serious misconduct and may lead to disciplinary action and legal consequences.

This provision does not apply to reports made in good faith that ultimately prove unfounded.

14. Governance and Oversight

The Whistleblowing Officer reports annually to Management on:

· Number of reports received

· Categories of reported concerns

· General outcome statistics

This report is anonymised and used for continuous improvement of governance and compliance systems.

15. Interaction with the Code of Conduct

This Policy forms an integral part of the 528 Ethics & Compliance Framework and should be read together with:

· Code of Conduct

· Anti-Corruption Policy

· Data Privacy Policy

· Sustainable Procurement Policy

16. Entry into Force

This Policy enters into force on January 1st 2026 and applies for an indefinite duration.