We take our legal and ethical responsibilities seriously. It is our policy to operate in accordance with applicable laws and regulations and our Code of Business Ethics and Conduct. Speaking up helps us to identify and address misconduct, improve our systems of governance, risk management and internal controls and to maintain the standards we set as a Group.

If you are concerned about misconduct, we encourage you to speak up as soon as possible, even if not all the facts are known. This allows us to look into the matter promptly and take any necessary action swiftly, especially where the potential misconduct or breach can still be prevented.

We always encourage everyone to speak up so that concerns can be dealt with appropriately. You have two ways of speaking up: you can raise your concerns to your line manager, HR or legal or alternatively you can make a formal report to your Ethics & Compliance (E&C) team or via the speak up service.

Many concerns can be effectively handled by raising these with your line manager, HR or legal or, if you are someone who has (or had) a business relationship with the Group, by raising your concerns with your Group contact.

However, if you have concerns that are in scope of our Speak Up Policy you may also make a report via the E&C team or the speak up service at [https://speakup.naspers.com] [https://speakup.prosus.com] or via the phone numbers listed on the website.

If you are unsure which is the best way to speak up, you can always discuss your options in confidence with your E&C Team.

When you raise a concern with your line manager, HR, legal or your Group contact, they can help you address the issue. If necessary, they can refer you to your Ethics & Compliance team for further information or advice.

Only concerns within the scope of the Speak Up Policy can be reported to the E&C team or via the speak up service. Making a formal report triggers a formal process. This is not the case when you raise concerns to your line manager, HR, legal or via your Group contact.

We always encourage you to speak up if you have concerns. You can speak up to your line manager, HR or legal on a variety of issues. You can make a formal report to Ethics & Compliance or via the speak up service any concerns about legal or ethical violations, including:

• breaches of competition laws and rules;
• breaches of privacy laws (with the exception of data security and other types of cyber incident - please refer to our Information Security website for further information on how to report those);
• breaches of sanctions or export control laws;
• bribery or corruption;
• conflicts of interest;
• discrimination or harassment;
• environmental or health and safety violations;
• fraud or theft;
• human rights violations;
• improper use of company resources;
• inadequate or improper financial or non-financial record keeping;
• insider trading;
• misuse of confidential information;
• money laundering or terrorism financing violations; and
• retaliation against anyone for speaking up.

Do not use the speak up service to report events that are an immediate threat to life or property. These should be reported to local authorities or emergency services.

If you have employment-related grievances, including performance-related issues, discussions on your terms of employment or other personal concerns, we recommend that you share those with your line manager or your HR contact directly. If you file a report through the speak up service on this type of concerns, it will be redirected to HR for handling; by approaching HR directly your concern can be handled faster.

We are committed to creating a culture where everyone feels safe to raise and discuss concerns and to protecting anyone who does so in good faith.

We do not tolerate any form of threat, retaliation or other action against anyone who has raised (or has helped someone to raise) a concern in good faith.

Any report made will be treated as confidential. This includes the reporter’s identity (if shared), the identity of any implicated individuals as well as any other non-public information.

We are committed to protecting the privacy of everyone involved in the speak up process (including anyone involved in an investigation). We will take appropriate measures to safeguard personal data from unauthorised access or use.

If you have concerns about legal or ethical misconduct and you have a business relationship with the Group (for example as a supplier or contractor), then we encourage you to speak up either via your Group contact or via the speak up service [https://speakup.naspers.com] [https://speakup.prosus.com].

If you are a customer, we encourage you to reach out to the relevant customer service team.

No. Customer complaints should be filed with the relevant customer service team. Customer complaints filed via the speak up service will be redirected to the relevant customer service team. By contacting the customer service department directly, your complaint will be handled faster.

You can speak up in confidence to your E&C team or submit a report via the speak up service either online at [https://speakup.naspers.com] [https://speakup.prosus.com] or on the phone via one of the phone numbers listed on the website. Your E&C team can also arrange a meeting where you can discuss your concerns or make a formal speak up report.

No. Our E&C teams and our speak up service supports multiple languages. On the speak up service webpage [https://speakup.naspers.com] [https://speakup.prosus.com] you can find local phone numbers which you can use to make a report in your local language.

The speak up service is operated by an independent provider and is available 24/7.

We encourage you to provide as much detailed information as you can, so that we can respond in the best possible way. Information that you provide is treated as confidential.

If you are comfortable doing so, we strongly encourage you to identify yourself. That way we can follow up with you directly if we have any additional questions and we can provide you with feedback and support.

Yes, you can provide documents whenever you make a formal report via the speak up service website or to your Ethics & Compliance team.

No. We encourage you to speak up as soon as you become aware of potential misconduct and share all the information you have. Do not investigate the matter yourself.

If you make a formal speak up report about possible misconduct in scope of our Speak Up Policy to your E&C team or the speak up service, you will receive a notification within 7 days to confirm that your report has been received.

Authorised members of the E&C team will review your report and may reach out to you with follow-up questions. They will then determine whether an investigation is required.

If an investigation is required, appropriately qualified investigators free of conflicts of interest will be appointed. Depending on the nature of your concern, this could be an E&C officer, member of the legal or risk & audit team or a member of another internal team, or it could be an external investigator. Under no circumstances, will we appoint anyone implicated in your concern or anyone with a conflict of interest.

Once the investigation is complete, we will get in touch to update you.

Speak up reports can only be accessed on a need-to-know basis by authorised members of the E&C, legal and risk & audit teams and, depending on the circumstances, external professional parties, all of whom have a duty of confidentiality. This will be kept to a small a group as possible. Under no circumstances will unauthorised staff have access to your speak up report.

Under certain laws, we may be required to disclose the details of a report and the results of an investigation. However, we will limit these disclosures to what is necessary.

If you have made a formal speak up report about possible misconduct in scope of our Speak Up Policy to your E&C team or the speak up service, you will receive a notification within 7 days to confirm that your report has been received.

We may reach out to you to ask additional questions or to provide any initial feedback.

We will always do our best to keep you updated on how your report is being handled. If an investigation is required, we will inform you as soon as we can and we will let you know if your concern was substantiated or not no later than three months. To the extent possible, we will also share if other measures have been taken as a consequence of the outcome of the investigation.

When we investigate very complex matters, it is possible that we may need more time to complete our investigation. If that is the case, we will still give you an update within three months and we will contact you again to share more information on the outcome of the investigation as soon as we have completed it.

We understand that speaking up is not easy. We do encourage you to identify yourself so that we can more easily reach out to you for follow-up questions and to provide support. If an investigation is required, this information may be shared with internal and/or external investigators, all of whom must be free of conflicts of interest and have a duty of confidentiality.

Where permitted by local law, you can choose to report concerns anonymously via our speak up service [https://speakup.naspers.com] [https://speakup.prosus.com]. If you choose to do so, please note down the unique report key that you are provided and the password you create at the time of submitting your concern – if we do not know your identity, this is our only way to communicate with you if we have follow-up questions or feedback.

We very much encourage you to identify yourself, but we would rather that you report your concern anonymously than not reporting at all.

The personal data you provide will be kept as long as necessary to process your report, or, if applicable, as long as necessary to take any follow-up actions or to meet the Group’s legal or financial needs, but in any case, not longer than allowed by applicable law.

If judicial or disciplinary proceedings are initiated, the personal data provided will be kept until those proceedings are definitively closed. Records of any disciplinary measures taken against an employee will be handled in compliance with Group procedures.

Whenever you report a concern via the speak up service (online or via the phone), you will be asked to create a password and you will receive a unique report key. You can use this key and password to log back in and check on our progress. If you chose to remain anonymous, logging in with the unique report key you received and the password you created is the only way that you can respond if we reach out with further questions or feedback.

To ensure that security and confidentiality is maintained, if you forget your report key or password, you will need to file a new report. Mention in the new report that it is related to a report you previously submitted.

If you are concerned about how a matter that you reported was handled, please contact the E&C team to discuss the options that you have (including the possibility of reporting the concern externally). Alternatively, you may contact the Group Speak Up & Investigations Lead at SpeakUp@prosus.com.

We believe our speak up process is robust and encourage everyone to report concerns internally. This gives us the opportunity to look into the matter, take necessary and appropriate action and to support you, where needed. However, this does not affect your right to raise concerns in an appropriate manner directly with a regulatory authority, where permitted by local law.

If you have any further questions that were not covered in this guide, you can reach out to the Group Speak Up & Investigations Lead at SpeakUp@prosus.com.

EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available. The internet portal never identifies a visitor and the EthicsPoint system strips away internet addresses.