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COMPLIANCE & ETHICS

Whistleblowing Policy

BFREE is committed to integrity, transparency, and accountability. We provide safe, confidential channels for employees, partners, and the public to report suspected misconduct — without fear of retaliation. This page summarizes our full Whistleblowing Policy, which governs how concerns are raised, investigated, and resolved.

Last updated: July 2, 2026.

What To Report

Raise a concern if you reasonably suspect:

Fraud, financial irregularity, or falsified records
Bribery, corruption, kickbacks, or facilitation payments
Violations of law, regulation, or our Code of Ethics
Insider trading or misuse of confidential information
Abuse of authority, coercion, or intimidation
Health, safety, or environmental risks
Undisclosed conflicts of interest, or concealment of any of the above

Outside This Policy

Personal grievances, performance concerns, and commercial disputes aren't covered here — please raise these with People & Culture or your line manager instead.

How To Report

Online Portal

Anonymous or named - 24/7 preferred channel

Direct to the Compliance Officer - monitored daily

Post (Sealed)

Company Address

Second Floor, Block C, Motorways Building, Alausa, Ikeja, Lagos.

Mark envelope “Private & Confidential”

Direct Report

Chief Compliance Officer

adenrele@bfree.africa

For concerns involving senior management

Anonymous Hotline

Phone/WhatsApp

+234 818 035 6133

No caller ID required - calls are not recorded

Anonymous reports are accepted via the Online Portal and Hotline. Reporters are encouraged to share as much detail as possible — dates, names, and evidence — to support a thorough investigation

Who Can Report

Eligibility: Employees and directors, contractors and consultants, suppliers and vendors, former employees and any third party connected to BFREE.

Your Protections

Confidentiality

Your identity is protected and won't be shared without consent, except where the law requires it.

No Retaliation

Anyone who retaliates against a good-faith reporter faces disciplinary action, up to dismissal.

Fair Process

Anyone named in a report is treated fairly, with a presumption of innocence and a right to respond.

What Happens Next

1

Acknowledged

Within 5 working days of receipt

2

Reviewed & Investigated

By a qualified, independent investigator

3

Findings Reported

To the Audit Committee / Board

4

Outcome Shared

With the reporter, where identifiable

Every report is handled objectively, fairly, and confidentially, with records retained for a minimum of 7 years. This summary highlights key points of the policy; the complete Whistleblowing Policy document governs in full.

See Something? Say Something.

Every concern raised in good faith will be heard, investigated, and protected.

Policy owner: Chief Compliance Officer / Ethics Committee · Oversight: Audit Committee of the Board · Reviewed annually