Whistleblowing
Policy

Last updated 15 Dec 2025

General OverviewGaulbridge Limited (“Gaulbridge”, “the Firm”, “we”, “us”) is committed to fostering a culture of transparency, accountability, and ethical business conduct by maintaining a secure and effective whistleblowing framework. This policy enables employees, clients, and stakeholders to report suspected misconduct, unethical behaviour, or regulatory breaches without fear of retaliation.The whistleblowing mechanism is designed to:Provide a confidential and secure reporting process for concerns related to market conduct, financial misconduct, conflicts of interest, or regulatory non-compliance.Ensure all reports are reviewed and investigated fairly, independently, and promptly, with appropriate corrective action taken where necessary.Prevent retaliation against whistleblowers, reinforcing the integrity of Gaulbridge’s governance and compliance standards.Align with applicable Canadian legal and regulatory expectations and recognised international best practices for whistleblower protection.

‍Scope and Applicability

‍This policy applies to all individuals who interact with Gaulbridge, including:Employees, executives, and directors (where applicable), including contractors and third-party service providers.Clients, vendors, and other stakeholders who wish to raise concerns relating to Gaulbridge’s activities.This policy covers reporting of suspected or actual violations, including (without limitation):Regulatory or compliance breaches (including AML/CTF concerns, sanctions issues, or improper onboarding/monitoring).Fraud, financial misconduct, misrepresentation, theft, or misuse of company or client assets.Conflicts of interest, corruption, bribery, improper inducements, or abuse of authority.Harassment, discrimination, bullying, or other serious workplace misconduct.Security incidents, unauthorised disclosures, data misuse, or improper handling of confidential information.Any other conduct that may materially harm the Firm’s integrity, reputation, clients, or regulatory standing.

‍Reporting Procedures and Confidentiality

‍To facilitate safe reporting, Gaulbridge provides multiple secure and confidential reporting channels:

‍Dedicated email: Reports may be submitted to compliance@gaulbridge.com (monitored by the Compliance function).

‍Anonymous reporting: Individuals may submit reports anonymously via a dedicated reporting mechanism (where available) or by written correspondence to our registered address:
‍
Gaulbridge Ltd
OFFICE 301
410 W GEORGIA ST
5TH FLOOR
VANCOUVER BC
V6B 1Z3
CANADA

‍Direct reporting: Individuals may report directly to the

‍Compliance Officer or a designated senior officer, in writing or by arranged meeting.Gaulbridge treats all reports with strict confidentiality. Whistleblowers may report anonymously, and identity will be protected to the fullest extent permitted by law. Unauthorised disclosure of a whistleblower’s identity is prohibited, except where disclosure is required by law or necessary for the Firm to meet legal or regulatory obligations.

‍Submission of Reports

‍To support a timely and effective review, whistleblowers should provide as much detail as possible, including:A clear description of the concern or suspected breachNames of individuals involved (if known)Dates, times, and locations (if applicable)Any available supporting evidence (documents, emails, screenshots, transaction references, etc.)Where a whistleblower chooses to remain anonymous, they may still provide evidence, provided this can be done safely and lawfully.

‍Investigation ProcessInitial Acknowledgement and Assessment

‍Where contact details are provided, Gaulbridge will acknowledge receipt within two (2) business days. Anonymous reports may be assigned a reference number (where feasible) to support follow-up.An initial assessment will be conducted to determine whether:the issue requires a formal investigation, and/oradditional information is required.

‍Formal Investigation

‍Where appropriate, a formal investigation will be initiated and managed by the Compliance function or a designated independent investigator. The investigation may include:

‍Evidence collection and review: relevant records, communications, system logs, and transaction information

‍Interviews and fact-finding: discussions with relevant individuals while maintaining confidentiality

‍Independent assessment: conducted by individuals not involved in the matter to ensure impartialityWhere suspected misconduct involves criminal behaviour, serious regulatory breaches, or legal infractions, the matter may be escalated to external authorities or relevant oversight bodies as required or appropriate under applicable law.

‍Resolution and Corrective Actions

‍Upon completion of an investigation, Gaulbridge will determine appropriate corrective actions, which may include:Disciplinary measures (warnings, suspension, termination, contract termination)Process and policy improvements to address control weaknesses or systemic riskRegulatory reporting and/or legal action where requiredWhere possible and lawful, Gaulbridge may provide the whistleblower with a high-level outcome update, noting that confidentiality and legal restrictions may limit what can be shared.

‍Whistleblower Protection and No Retaliation

‍Gaulbridge has a strict zero-tolerance approach to retaliation against individuals who raise concerns in good faith.Retaliation includes, but is not limited to:Termination, demotion, suspension, or adverse changes to dutiesHarassment, intimidation, threats, or pressure to withdraw a reportUnjustified disciplinary actions or negative treatment due to reportingAny person who experiences or observes retaliation should report it immediately through the channels above. Gaulbridge will investigate retaliation allegations and take appropriate action.While Gaulbridge encourages good faith reporting, knowingly false, malicious, or deliberately misleading reports may result in disciplinary or contractual consequences.

‍Reporting and Record-Keeping

‍All whistleblower reports, investigation materials, and outcomes are securely stored with restricted access and retained for a minimum period of eight (8) years, or longer where required by law or regulatory expectations.Gaulbridge ensures that:Reports remain confidential and are accessible only to authorised personnelPeriodic summaries (without identifying information) may be provided to senior management and, where applicable, the Board for governance oversightRecords may be provided to regulators or authorities where required by law

‍Ongoing Review and Monitoring

‍To maintain an effective whistleblowing framework, Gaulbridge reviews this policy at least annually, and more frequently where required due to:

Regulatory or legal changesMaterial changes to business operations, services, or risk exposure
‍
Lessons learned from whistleblower investigations
‍
As part of Gaulbridge’s broader compliance program:

Staff training and awareness initiatives support ethical behaviour and safe reporting
Periodic audits and controls testing may be conducted to validate effectiveness and confidentiality