WHISTLEBLOWINGPOLICY

Helpex Pay Ltd.

Company number

BC1594027

FINTRAC MSB registration

N300001747

Registered address

2120-580 Seaborne Avenue, Port Coquitlam, British Columbia, Canada, V3B 0M3

Website

https://helpex.exchange

Effective date: 7 November 2026

This Policy explains how concerns about suspected wrongdoing, misconduct or serious risks connected with Helpex Pay Ltd. may be reported and how reports will be handled.

1. Purpose

Helpex Pay Ltd. (the “Company”, “Helpex”, “we”, “us” or “our”) is committed to conducting its business lawfully, ethically and responsibly. This Whistleblowing Policy (the “Policy”) provides a channel for raising genuine concerns about suspected wrongdoing, misconduct, legal or regulatory breaches, or serious risks connected with the Company’s activities.

The purpose of this Policy is to encourage people to speak up, explain the safeguards that may apply to reporters, and describe the general process for reviewing and addressing reports.

2. Scope and Who May Report

This Policy applies to concerns relating to the Company, its business, personnel, contractors, representatives, suppliers and other persons acting on its behalf. A report may be made by, among others:

• current or former employees, officers, directors and job applicants;
• contractors, consultants, agents and temporary personnel;
• suppliers, service providers, business partners and their personnel; and
• other individuals who obtain information about a concern through a work-related or business relationship with the Company.

A person does not need to be an employee of the Company to raise a concern under this Policy.

3. Matters That May Be Reported

A report may concern actual, suspected or attempted wrongdoing, including:

• fraud, theft, bribery, corruption, kickbacks, money laundering or terrorist financing;
• breaches of applicable laws, regulations, sanctions requirements or regulatory obligations;
• deliberate or serious breaches of the Company’s policies, controls or contractual obligations;
• misuse of customer funds, confidential information, personal information or Company assets;
• dishonest, deceptive, abusive, discriminatory, harassing or seriously unethical conduct;
• conflicts of interest, improper influence, retaliation or concealment of wrongdoing;
• serious cybersecurity, data protection, information security or operational control failures; and
• attempts to suppress, destroy or conceal information relating to any of the above.

This Policy is not intended to replace ordinary customer support or complaints procedures for routine service issues, exchange execution, fees or account access. Customers may use help@helpex.exchange for general support and complaints may be sent to complaints@helpex.exchange. If a customer concern also indicates suspected serious wrongdoing, it may be reported under this Policy.

4. Reporting Channel

Reports should be submitted through the Company’s designated whistleblowing channel:

whistle@helpex.exchange

Reports may be submitted to the Company’s dedicated whistleblowing email address: whistle@helpex.exchange. This channel should be monitored by an appropriate person who is sufficiently independent of the subject matter of the report.

If the designated channel is unavailable or the report concerns the person responsible for receiving reports, the reporter should use an alternative reporting route established by the Company or, where appropriate, contact a competent external authority.

5. Information to Include in a Report

To help the Company assess a report, the reporter is encouraged to provide, where available:

• a clear description of the concern and why it is believed to involve wrongdoing;
• the names or roles of persons involved, if known;
• relevant dates, locations, transactions, systems or business areas;
• supporting documents, messages or other evidence that the reporter is lawfully entitled to share; and
• whether the concern is ongoing, urgent or presents an immediate risk.

A report may be made even if the reporter does not have all of this information. Reporters should distinguish facts from assumptions or personal opinions and should not conduct their own investigation or obtain information unlawfully.

6. Anonymous Reports

The Company may accept anonymous reports. A reporter who wishes to remain anonymous should avoid including information that would unnecessarily identify them. The Company may be limited in its ability to investigate or provide feedback where it cannot ask follow-up questions.

Where the reporting channel permits, an anonymous reporter is encouraged to provide a secure means of two-way communication without disclosing their identity.

7. Confidentiality and Protection of Information

The Company will handle reports and related information discreetly and will seek to limit access to individuals who need the information to assess, investigate, respond to or oversee the matter, or where disclosure is required or permitted by law.

The Company cannot guarantee absolute confidentiality in every circumstance. Information may need to be disclosed to professional advisers, auditors, regulators, law enforcement agencies, courts or other persons where necessary or legally required. The Company will seek to avoid identifying a reporter unnecessarily and, where appropriate, will inform the reporter before disclosure unless prohibited by law or doing so could prejudice an investigation.

Personal information contained in a report will be handled in accordance with applicable privacy and data protection laws and the Company’s Privacy Policy.

8. Non-Retaliation

The Company prohibits retaliation against a person who, in good faith, raises a concern, assists with an investigation, or refuses to participate in suspected wrongdoing. Retaliation may include dismissal, demotion, threats, harassment, intimidation, discrimination, adverse changes to working arrangements, blacklisting or other detrimental treatment.

Any suspected retaliation should be reported promptly through the designated whistleblowing channel. Allegations of retaliation will be treated seriously and may themselves result in disciplinary, contractual or other appropriate action.

This Policy does not prevent a person from exercising any rights or protections available under applicable whistleblower, employment, labour or other laws.

9. Good-Faith Reporting and Misuse

Reports should be made honestly and on a reasonable basis. A reporter does not need to prove the concern; the Company will assess the information provided. A person who makes a report in good faith will not be penalised merely because the concern is not substantiated.

Knowingly false, malicious or deliberately misleading reports, or the deliberate fabrication or alteration of evidence, may result in appropriate action. An unsubstantiated report is not, by itself, evidence that it was made in bad faith.

10. Review and Investigation Process

Upon receipt, the Company will, as appropriate:

• acknowledge receipt where contact details or a secure reply route are available;
• make an initial assessment of the nature, seriousness and urgency of the concern;
• identify and manage conflicts of interest, including appointing an alternative reviewer where necessary;
• determine whether an internal review, independent investigation or referral to an external authority is appropriate;
• preserve relevant records and take proportionate steps to prevent ongoing harm or interference;
• conduct enquiries fairly and, where appropriate, give persons affected an opportunity to respond; and
• record the outcome and consider corrective, disciplinary, control or remediation measures.

The Company may decide not to investigate a report further where it is clearly outside the scope of this Policy, is unsupported by sufficient information to permit meaningful enquiries, is duplicative of a matter already addressed, or where another process or authority is more appropriate. The reasons for such a decision should be documented where appropriate.

11. Acknowledgement, Updates and Outcomes

Where practicable and legally permissible, the Company will acknowledge a report and may provide reasonable updates on its progress. The time required to review a report will depend on its complexity, urgency, availability of evidence and any external process.

The Company may provide the reporter with a general outcome or confirmation that the matter has been addressed. Detailed findings, disciplinary measures, personal information about others, legally privileged material and confidential business information may not be disclosed.

12. External Reporting

Nothing in this Policy prevents a person from reporting a concern directly to a competent regulator, law enforcement agency or other public authority, or from seeking independent legal advice. A person may have statutory rights to make a protected disclosure under applicable law. The Company does not require a person to report internally before making a report to an external authority where the law permits direct external reporting.

Where a concern may involve an immediate threat to personal safety, serious criminal conduct or an urgent risk to customers or the public, the reporter should contact the appropriate emergency service or competent authority without delay.

13. Records and Retention

The Company will maintain records of reports, assessments, investigations and outcomes in a manner proportionate to the nature of the matter and in accordance with applicable legal, regulatory, privacy and record-retention requirements. Access to such records will be restricted to authorised persons.

Records will not be retained longer than necessary for the relevant purposes, except where a longer retention period is required or permitted by law, or is necessary to establish, exercise or defend legal claims.

14. Responsibilities

The Company’s management is responsible for supporting an effective speak-up culture, ensuring that reports are handled appropriately, and taking reasonable steps to prevent retaliation. Persons assigned to receive or investigate reports must act impartially, maintain confidentiality, disclose conflicts of interest and escalate matters where necessary.

All persons within the scope of this Policy are expected to cooperate honestly with a lawful investigation and must not destroy, conceal or improperly alter relevant information.

15. Relationship with Other Policies

This Policy should be read together with the Company’s Terms and Conditions, Privacy Policy, and other applicable internal policies and procedures. If there is a conflict between this Policy and a mandatory legal requirement, the legal requirement will prevail.

This Policy describes the Company’s general approach and does not create contractual rights or limit any rights or remedies that cannot lawfully be excluded.

16. Changes to This Policy

The Company may update this Policy from time to time to reflect changes in its business, reporting arrangements or applicable legal and regulatory requirements. The current version will be made available on the Company’s website. The effective date is shown at the beginning of the Policy.

17. Contact Details

For general questions about this Policy, contact:

Helpex Pay Ltd.

Email: help@helpex.exchange

Website: https://helpex.exchange

Address: 2120-580 Seaborne Avenue, Port Coquitlam, British Columbia, Canada, V3B 0M3

Whistleblowing reports may be sent to whistle@helpex.exchange.