Policies

Last Updated: January 2026

This Whistleblowing Policy outlines how individuals outside of the Nxera organisation can raise concerns about wrongdoing connected to our operations. We are committed to conducting our business ethically, responsibly, and in compliance with all applicable laws. We take all genuine concerns raised under this Policy seriously and ensure they are handled fairly, confidentially, and without retaliation.

Who this Policy applies to

This Policy applies to anyone external in the organisation, including: vendors and suppliers, job applicants, former employees, community members and other third parties.

What types of concerns should be reported under this policy?

We encourage genuine whistleblowing concerns to be made under this Policy. Whistleblowing is the disclosure of information which tends to show that:

• a criminal offence has been committed, is being committed or is likely to be committed (this may include: theft, including theft of IP; fraud; bribery and corruption; breaches of health & safety legislation; human trafficking; environmental offences; money laundering; and tax evasion);
• a person has failed, is failing or is likely to fail to comply with a legal obligation to which he or she is subject (this may include: regulatory breaches; data protection breaches; tax evasion; health & safety breaches; employment law breaches; and environmental law breaches);
• a miscarriage of justice has occurred, is occurring or is likely to occur;
• the health or safety of any individual has been, is being or is likely to be endangered;
• the environment has been, is being or is likely to be damaged; and/or
• information tending to show any matter falling within one of the above sets of circumstances has been, is being or is likely to be deliberately concealed.

Other grievances (eg contract disputes) are generally not covered by this Policy unless they involve broader misconduct.

Raising a whistleblowing concern

Reports can be made confidentially via Nxera’s external independent whistleblowing service called EthicsPoint via the following means:

PC/Web - nxera.ethicspoint.com

Mobile/Web - nxera.navexone.eu/intake

Telephone

• United Kingdom – 0808 281 3457
• Japan – 0120 983 379
• South Korea – 00744862
• Switzerland – 0800 040 015

You may report anonymously with EthicsPoint, although providing contact details can help us investigate more effectively.