Of Katanox B.V., the ultimate parent company of the Katanox Group, a private limited liability company under the laws of the Netherlands, having its official seat in Amsterdam, the Netherlands, and its office address at Kleine Gartmanplantsoen 21-6th floor, 1017 RP Amsterdam, the Netherlands, registered with the Commercial Register of the Chamber of Commerce under number 75629763 which includes:

Katanox Financial Technology BV, a Dutch private limited liability company, wholly owned by Katanox B.V., having its office address at Kleine-Gartmanplantsoen 21-6, 1017 RP Amsterdam, the Netherlands, registered with the Commercial Register of the Chamber of Commerce under number; 85692549 licensed Payment Service Provider for the European Economic Area by the Dutch National Bank under number: 724500GLLXB682M9DD36

Katanox Financial Technology Ltd. a British private limited liability company, wholly owned by Katanox B.V., having its office address at 2 Eastbourne Terrace, London W2 6LG, United Kingdom, registered with the Companies House under number; 14423621

Katanox Financial Technology Inc. a company organised under the laws of Delaware, United States, wholly owned by Katanox, having its office address at 500, 7th Avenue, New York, 10018, registered with FinCEN as a Money Services Business under number: 31000246128534

hereinafter referred to as “Katanox”.

Introduction

Our values “See it, own it” and "Practice Radical Candor” apply in all our dealings within Katanox, and when we work with clients, partners and vendors.

Purpose

We expect the highest ethical standards across our businesses, so there may be occasions where any of our colleagues wish to report suspected wrongdoing. The aim of this Policy is to provide mechanisms for reporting and investigating such concerns.

This Policy is to support:

• A culture of authenticity and responsibility;
• The reporting of suspected wrongdoing, knowing that concerns will be taken seriously and investigated as appropriate, whilst respecting confidentiality;
• The methods of raising a concern; and
• The principle of non-retaliation.

Scope

This Policy applies to Katanox BV and to all subsidiaries in which it holds, directly or indirectly, a majority shareholding or exercises effective control, collectively called ‘Katanox’ or the ‘Company’.

This Policy also applies to all individuals working full time or part time at all levels within the Company, as well as those performing work for the Company such as agency workers, self-employed contractors, part-time and fixed-term workers, interns, collectively referred to as ‘employees’.

Principles

Anonymity