Newrails UAB Whistleblowing notice

Purpose

This Whistleblowing Notice ensures that everyone associated with Newrails UAB (Newrails) can report concerns about possible breaches of law or company policies in a safe and secure manner, without fear of retaliation.

Ambr maintains a zero tolerance approach to bribery and corruption and is committed to integrity, transparency and accountability in all business activities.

Who Can Report?

This notice applies to:

• Employees (current and former)
• Members of the Management Board and Supervisory Board
• Outsourced function performing staff
• Contractors, consultants, volunteers, interns and similar roles
• Business partners and vendors acting for or on behalf of Ambr

What Can Be Reported?

You can report in good faith any serious concern related to Newrails, including:

• Legal violations: breaches of applicable laws or regulations
• Bribery and corruption: offering, giving, requesting or accepting undue advantages, facilitation payments, improper influence on public officials
• Financial crime and compliance breaches: money laundering, terrorist financing, fraud, misuse of company or client assets
• Conflicts of interest and unethical behaviour: undisclosed conflicts, unlawful gifts, hospitality or entertainment, misuse of company resources for political or personal purposes
• Policy violations: serious breaches of the Anti Bribery and Anti Corruption Policy, Code of Conduct or other internal policies
• Any other acts that may be in breach of applicable laws or Newrails internal policies

Day to day HR type issues that do not involve a breach of law or policy should normally be raised through HR or line management, unless they also involve matters listed above.

How to Report?

You can report concerns through the following channels:

Internal Reporting

• Anonymous Reporting Channel
  • Email: whistleblowing@ambrpayments.com
  • Mail: Mark it "To the Head of Compliance" Svitrigailos 11C Vilnius, Lithuania
  • Access: CCO and or MLRO
• Direct Supervisor or Manager
  • If appropriate and if this does not compromise confidentiality, independence or objectivity

External Reporting

• Report directly to the Bank of Lithuania or other competent authorities. Guidance is available here: https://www.lb.lt/en/forms/reporting-of-breaches-of-legal-acts-regulating-the-financial-market#ex-1-7

Your Rights as a Whistleblower

• Confidentiality: Your identity and any information that could identify you will be protected to the greatest extent possible and only shared with those who need it to handle the report or comply with legal obligations.
• Protection Against Retaliation: No adverse actions such as dismissal, demotion or harassment will be taken against you for reporting in good faith or assisting in an investigation.
• Anonymous Reporting: You may report anonymously. Anonymous reports will be treated seriously, though the ability to investigate may be limited if further information is needed.
• Right to Know the Outcome: Where possible and subject to legal and privacy restrictions, you may be informed that the investigation has been completed and whether general corrective measures were taken.

How We Handle Reports

• Acknowledgment: Where contact details are available, receipt of your report will be acknowledged within a reasonable time.
• Assessment: The Compliance function will review the report within 14 business days to determine if it falls under this notice and whether further information is needed.
• Investigation: If appropriate, a confidential and impartial investigation will be carried out within 30 business days. Relevant documents, systems and witnesses may be reviewed.
• Outcome and Remediation: Findings and any corrective, disciplinary or legal actions will be documented. Serious matters may be escalated to the Management Board or competent authorities.

False or Malicious Allegations

Newrails encourages reporting of genuine concerns in good faith, even if they later prove unfounded.

Knowingly submitting false or malicious allegations is not tolerated and may result in disciplinary action or other appropriate measures.

Training and Awareness

Newrails will provide regular training and communication on:

• The Anti Bribery and Anti Corruption Policy
• Whistleblowing channels and protections

Training is organised by the CCO and provided at least once a year and whenever material changes to relevant policies or procedures occur.

Record Keeping

All whistleblowing reports and related documentation will be stored securely in line with legal and regulatory requirements and internal retention rules.

Access to these records is restricted to authorised persons who need the information for compliance, investigation, legal or supervisory purposes.