Whistleblower Policy

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At IceRide, we are committed to fostering an open, transparent, and ethical workplace where employees, contractors, and third-party partners can report any unethical behavior, misconduct, or legal violations without fear of retaliation. The Whistleblower Policy establishes a formal process for individuals to confidentially report concerns about illegal or unethical conduct, ensuring their protection from any adverse consequences.

1. PurposeThe purpose of this Whistleblower Policy is to provide employees and other stakeholders with a clear and accessible process for reporting concerns about violations of the law, unethical behavior, or any actions that are not aligned with the core values of IceRide. We take all concerns seriously and will investigate all reports diligently and thoroughly.

2. ScopeThis policy applies to all employees, contractors, vendors, partners, and any other stakeholders of IceRide. It covers concerns related to:

• Financial fraud or irregularities
• Violations of company policies, including but not limited to safety and compliance
• Discrimination, harassment, or workplace bullying
• Illegal activities, including theft or corruption
• Health and safety violations
• Any other unethical or improper conduct

3. Reporting ProcessEmployees and stakeholders are encouraged to report any concerns in good faith through one of the following channels:

• Anonymous Whistleblower Hotline: Reports can be made anonymously through the company's whistleblower hotline, accessible via phone or online form.
• Direct Reporting: Employees can report concerns directly to their manager, the Human Resources department, or the Legal and Compliance team.
• Third-Party Reporting: IceRide has engaged an independent third party to handle confidential whistleblower reports to ensure anonymity and unbiased review.

Reports should include sufficient details to facilitate a proper investigation. The reporter does not need to prove the validity of their concern, but reports should be made with reasonable belief that a violation has occurred.

4. ConfidentialityIceRide is committed to maintaining the confidentiality of all whistleblower reports to the extent possible. The identity of the whistleblower will not be disclosed unless required by law or necessary for a thorough investigation. Any individual involved in investigating the report will be bound by strict confidentiality protocols.

5. Protection Against RetaliationWhistleblowers are protected from retaliation under this policy. IceRide prohibits any form of retaliation, including but not limited to:

• Demotion
• Harassment
• Termination
• Discrimination
• Adverse employment consequences

Any employee who engages in retaliatory behavior will be subject to disciplinary action, up to and including termination.

6. Investigation and Follow-UpOnce a report is received, the Legal and Compliance team or a designated third-party investigator will conduct a prompt and thorough investigation. This may include interviews, document reviews, and any other relevant investigative procedures. Upon completion of the investigation, appropriate action will be taken based on the findings.

If a report is found to be false or maliciously made, IceRide reserves the right to take disciplinary action against the individual responsible for the false report.

7. Reporting OutcomesWhistleblowers will be informed about the outcome of the investigation, within the bounds of confidentiality, to assure that the matter has been addressed appropriately. In certain cases, it may not be possible to disclose full details of the investigation due to privacy and legal constraints.

8. Good Faith ReportingThis policy encourages reporting in good faith. Whistleblowers who have reason to believe that misconduct has occurred and report it in good faith will be protected from any form of retaliation. However, any reports made with malicious intent, or with knowledge of being false, will result in disciplinary action.

9. Training and AwarenessIceRide provides regular training on the Whistleblower Policy to ensure that all employees are aware of their rights and responsibilities. Information about the policy will also be made available on the company’s intranet and communicated to new employees during onboarding.

10. Review and UpdatesThis policy will be reviewed annually or as necessary to reflect any changes in laws, regulations, or company practices. Any updates to the policy will be communicated to employees and stakeholders promptly.

For more information or to report a concern, please contact:

IceRide Legal and Compliance Team
Email: compliance@iceinnovations.ai
Address: 5000 CentreGreen Way, Suite 500, Cary, North Carolina 27513