Procedure for Reporting and Following up on Breaches effective as of 18 September 2024 for BETTER COLLECTIVE POLAND Sp. z o.o. Table of contents I. Introduction II. Definitions III. Internal reporting procedure IV. Internal Reporting channels V. Internal Reporting Register VI. External Reporting and Public Disclosure VII. Prohibition of retaliation VIII. Personal data IX. Final provisions I. Introduction 1. This procedure defines the activities, actions, and measures undertaken to protect Whistleblowers reporting or disclosing information on breaches of the law to the public, and how such activities, actions, and measures are implemented following the law at BETTER COLLECTIVE POLAND Sp. z o.o. based in Kraków, ul. Mogilska 43, 31-545 Kraków, entered in the Register of Entrepreneurs of the National Court Register under no. 0000757006, NIP (Tax ID): 5252770183, REGON (Business ID): 38177660400000, registry court: District Court for the Capital City of Warsaw, 12th Commercial Division of the National Court Register (hereinafter referred to as the “Legal Entity”). The Legal Entity shall establish an internal procedure for internal reporting of breaches and follow-up, hereinafter referred to as the “Internal Reporting Procedure”. 2. The Legal Entity shall monitor the implementation of this Procedure, on its own or through persons it has individually appointed, as the case may require. 3. The Legal Entity shall ensure that the Whistleblower’s identity is kept confidential. The procedures implemented to ensure the aforementioned protection are described in the GDPR procedures adopted by the Legal Entity and in Chapter VIII of the Procedure. 4. The Legal Entity has adopted the procedure following consultation with representatives of persons providing work to the Legal Entity, selected in accordance with the procedure adopted by the Legal Entity. 5. The Procedure applies to all staff members of the Company, regardless of the form and type of employment, including any staff responsible within the Legal Entity for performing duties within the scope of this Procedure. 6. The Procedure also applies to applicants for a job under an employment or any other legal relationship giving rise to the provision of work or services, the exercise of a function or service, as soon as the recruitment procedure or pre-contractual negotiations commence. 7. To confirm familiarity with and commitment to adhere to the Procedure, it is necessary to sign a statement via Company’s intranet - BC.Rocks, and in the case of the recruitment process, a via separate statement. For online and remote recruitment processes, the candidate shall accept the established procedure and declare that he or she has read and agrees to adhere to the Procedure either by ticking the relevant checkbox on the Legal Entity’s recruitment page or by sending an e-mail to: recruitment_poland@bettercollective.com 8. Persons performing their duties under the Act and the Procedure shall also keep confidential the information they obtain while performing their activities within the scope of the Procedure. The obligation shall survive the termination of the employment relationship or the discontinuation of activities under civil law agreements. II. Definitions 1. Contact Address – means the correspondence address or e-mail address of the Whistleblower provided in the course of Internal Reporting. 2. Personal Data – mean any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; 3. Follow-up – means any action taken by the Legal Entity to assess the accuracy of the allegations made in a Report and to address the breach of the law reported as part of Internal Reporting; 4. Retaliation or Reprisal – means any direct or indirect act or omission which occurs in a work-related context, is prompted by Internal Reporting or by public disclosure, and which causes or may cause unjustified detriment to the Whistleblower, including the unjustified initiation of proceedings against the Whistleblower; 5. Feedback – means the provision to the Whistleblower of information on the action envisaged or taken as Follow-up and on the grounds for such Follow-up 6. Information on breaches – means information, including reasonable suspicions, about actual or potential breaches, which occurred or are very likely to occur in the Legal Entity in which the Whistleblower has participated in a recruitment procedure or other pre-contractual negotiations, works or has worked or in another legal entity with which the Whistleblower is or has been in contact through his or her work, and about attempts to conceal such breaches; 7. Work-related context – means current, past or future work activities under an employment or any other legal relationship providing the basis for the provision of work or services or the exercise of functions in or for the Legal Entity, or service in the Legal Entity, through which persons acquire information on breaches and within which those persons could suffer Retaliation; 8. Breach – means an act or an omission that is unlawful or intended to circumvent the law concerning the following areas: corruption, public procurement, financial services, products and markets, prevention of money laundering and terrorist financing, product safety and compliance, transport safety, protection of the environment, radiological and nuclear safety, food and feed safety, animal health and welfare, public health, consumer protection, protection of privacy and personal data, security of network and information systems, financial interests of the State Treasury of the Republic of Poland, a local government unit and the European Union, the European Union internal market, including the public law principles of competition and state aid and corporate taxation, constitutional freedoms and human and civil rights, arising in relations between an individual and public authorities and not related to the areas indicated above. 9. Facilitator – means a natural person who assists a Whistleblower in the reporting or public disclosure process in a work-related context, and whose assistance should be confidential; 10. Person related to the whistleblower – means a natural person who may suffer retaliation, including an associate or a relative of the Whistleblower as defined in Article 115 § 11 of the Act of 6 June 1997 - Penal Code (Journal of Laws of 2024, item 17) 11. Person concerned – means a natural person, a legal person or an organisational unit without legal personality, granted legal capacity by the law, who is referred to in the report or public disclosure as a person to whom the breach is attributed or with whom that person is associated; 12. Legal Entity – BETTER COLLECTIVE POLAND Sp. z o.o. based in Kraków, ul. Mogilska 43, 31-545 4 Kraków, entered in the Register of Entrepreneurs of the National Court Register under number 0000757006, NIP (Tax ID): 5252770183, REGON (Business ID): 38177660400000, registry court: District Court for the Capital City of Warsaw, 12th Commercial Division of the National Court Register, with a share capital of PLN 5,000.00. 13. Procedure – the procedure for reporting and following up on information on breaches of the law, pursuant to Article 24 of the Act; 14. Whistleblower – means a natural person who reports or publicly discloses information on breaches in the context of his or her work-related activities, including a natural person who reports or publicly discloses information on breaches in the context of his or her work-related activities prior to the establishment of an employment relationship or any other legal relationship giving rise to the provision of work or services, the exercise of functions in or for the legal entity, or service in the legal entity, or after termination thereof. 15. Act – means the Polish Act of 14 June 2024 on Whistleblower Protection (Journal of Laws of 2024, item 928) of 24 June 2024 16. Internal Reporting – means the oral or written communication of information on breaches of the law within a legal entity 17. External Reporting – means the oral or written communication of information on breaches of the law to the Ombudsman or a public authority

III. Internal reporting procedure 1. The person authorised within the Legal Entity's organisational structure to receive reports made through internal reporting channels is Cezary Brzuzy. 2. Internal Reporting channels for Whistleblowers, who may provide their Contact Address or not: a) A Whistleblower may make a report orally (by telephone or by electronic means as defined in Article 2(5) of the Act of 18 July 2002 on Electronic Provision of Services) – each report made in this form shall be documented with accurate minutes of the conversation or a screenshot of the report. Contact details for reporting are as follows: e-mail: cbrzuzy@bettercollective.com telephone: +48 531 353 223 b) Upon request by the Whistleblower, oral reporting shall be possible at a physical meeting held within 14 days of receipt of the request. In this case, with the Whistleblower’s consent, the oral reporting shall be documented in one of the following ways: 1) by making a recording of the conversation in a retrievable form; or 2) through a complete and accurate transcript of the meeting, drafted by am authorised person based of the document referred to in section c) A Whistleblower may make a report in writing to Cezary Brzuzy, Better Collective Poland Sp zo.o. ul. Mogilska 43, 31-545 Kraków, 8 piętro. The envelope should be marked with a note “WHISTLEBLOWER”. 3. In the case referred to in sections 2(a) and 2(b)(2), the Whistleblower shall have the opportunity to check, rectify and agree the recording of the conversation or the minutes of the meeting by signing them. 4. The person within the Legal Entity’s organisational structure referred to in section 1 shall confirm the receipt of the report to the Whistleblower within 7 days of its receipt, except where the Whistleblower has not provided his or her Contact Address to which the confirmation should be sent. IV. Internal Reporting channels 1. The person within the Legal Entity’s organisational structure referred to in Chapter III, section 1, shall forward a report made through Internal Reporting channels to the impartial internal organisational unit authorised to verify and follow up on the report within 7 days from the date of the Internal Reporting. 2. The impartial internal organisational unit authorised to carry out follow-up activities shall consist of the following persons: ● Jakub Matuszyk, jmatuszyk@bettercollective.com ● Konrad Perkowski, kperkowski@bettercollective.com ● Ewelina Grądzka, egradzka@bettercollective.com who are also available at the collective email address whistleblower_poland@bettercollective.com 3. The authorisation to carry out follow-up activities for the Entity referred to in section 2 shall include, in particular, the following: a) verifying Internal Reporting, in particular the accuracy of allegations, b) further communication with the Whistleblower, including requests for further information necessary for verifying Internal Reporting, c) taking action with due diligence to prevent the breach of the law reported as part of Internal Reporting, in particular through an investigation, the initiation of an audit or administrative proceedings, prosecution, or an action taken for recovery of funds; d) providing feedback to the Whistleblower on how their report made through an Internal Reporting channel has been assessed and what follow-up activities are carried out. 4. The maximum time limit for providing feedback to the Whistleblower must not be more than 3 months from the date of acknowledgement of the Internal Reporting or, in the absence of this, 3 months from the expiry of 7 days from the date of the Whistleblower’s Internal Reporting, except where the Whistleblower has not provided a contact address to which the acknowledgement should be sent. V. Internal Reporting Register 1. The Legal Entity shall maintain an internal reporting register. The Internal Reporting Register shall include, in particular, the following: a) the number of the Report; b) the subject matter of the breach; c) the personal data of the Whistleblower and the person concerned necessary to identify them; d) the Whistleblower’s contact address; e) the date of the Report; f) information on follow-up; g) the date of closure of the case. 2. The individual sections of the Register shall be filled out by the entities referred to in Chapter III, section 1 – Person within the Legal Entity’s organisational structure and in Chapter IV, section 2 – Impartial internal organisational unit authorised to carry out follow-up activities, depending on their competence as part of the report made internally.

VI. External Reporting and Public Disclosure 1. The Whistleblower may report information on breaches through an External Reporting channel without first using an Internal Reporting channel. Information on breaches reported through an External Reporting Channel shall be received by either the Ombudsman or a public authority, including a European Union body, in the manner specified for the competent entity. 2. Whistleblowers who make a public disclosure shall be protected in the following cases: a) the Whistleblower first reports internally and then externally, and the Legal Entity and, next, the public authority carry out no appropriate follow-up activities or provide no feedback to the Whistleblower within the timeframe for providing feedback established in the internal procedure and then within the timeframe for feedback established in the public authority’s external procedure, or b) reports directly externally, and the public authority carries out no appropriate follow-up activities or provides no feedback to the Whistleblower within the time limit established for providing feedback in its external procedure, except where the Whistleblower has not provided his or her contact address to which the feedback should be sent. 3. A Whistleblower who makes a public disclosure shall also qualify for protection if they have reasonable grounds to believe that: a) the breach may constitute an imminent or manifest danger to the public interest, such as where there is an emergency situation or a risk of irreversible damage; or b) in the case of external reporting, there is a risk of retaliation, or c) in the case of external reporting, there is a low prospect of the breach being effectively addressed, due to the particular circumstances of the case, such as those where evidence may be concealed or destroyed or where an authority may be in collusion with the perpetrator of the breach or involved in the breach.

VII. Prohibition of retaliation 1. The Legal Entity strictly prohibits any retaliation against a Whistleblower who has reported information on breaches through Internal Reporting channels, in accordance with the Act. 2. Any retaliatory, discriminatory or otherwise unfair treatment towards a Whistleblower shall be treated as a breach of this Procedure and may result in disciplinary liability or termination of the agreement between the retaliator and the Legal Entity. 3. It is, in particular, unacceptable to do the following in relation to a Whistleblower: 1) if work has been, is being or is due to be performed based on an employment relationship, no retaliation may be taken against the Whistleblower, involving, in particular, the following: a) refusal to establish an employment relationship; b) termination of the employment relationship with or without notice; c) failure to conclude an employment contract for a definite term or an employment contract for an indefinite term after the termination of a contract for a trial period, failure to conclude another employment contract for a definite term or failure to conclude an employment contract for an indefinite term after the termination of an employment contract for a definite term where the Whistleblower had legitimate expectations that such contract would be concluded with him or her; d) reduction in the amount of remuneration for work; e) withholding promotion or passing over for promotion; f) passing over for work-related benefits other than salary or wage or reduction in the amount of such benefits; g) demotion; h) suspension in the performance of employee or professional duties; i) assigning the Whistleblower’s existing duties to another worker; j) a disadvantageous change in the place of work or working time schedule; k) a negative performance assessment or employment reference; l) imposition or administering of any disciplinary measure, including a financial penalty or any similar measure; m) coercion, intimidation or ostracism; n) harassment, discrimination, disadvantageous or unfair treatment; o) withholding of participation or passing over for professional improvement training; p) unjustified referral for medical examinations, including psychiatric examinations, except where separate provisions provide for the possibility of referring a worker for such examinations; q) blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may entail that the person will not, in the future, find employment in the sector or industry; r) causing financial loss, including loss of business and loss of income; s) harm, including a violation of the person’s moral rights, including reputational damage to the Whistleblower. 2) Retaliation for making a report is also deemed to include attempts or threats of resorting to the measure referred to above. 3) if the work or services were, are or are due to be provided on the basis of a legal relationship other than an employment relationship constituting the basis for the provision of the work or services or the exercise of functions, the above provisions shall apply accordingly, insofar as the nature of the work or services provided or the exercise of functions does not render such action inapplicable to the Whistleblower. 4) if the work or services were, are or are due to be provided on the basis of a legal relationship other than an employment relationship constituting the basis for the provision of the work or services or the exercise of functions, no Internal Reporting may give rise to any Retaliation or an attempt or threat of Retaliation, including, in particular the following: a) the termination of an agreement to which the Whistleblower is a party, in particular one relating to the sale or supply of goods or the provision of services, withdrawal from such an agreement or termination thereof without notice; b) the imposition of an obligation or refusal to grant, restriction or withdrawal of a right, in particular a licence, permit or relief. 4. A Whistleblower who has suffered Retaliation shall have the right to compensation in an amount not lower than the average monthly remuneration in the national economy in the previous year, announced for old-age pension purposes in the “Monitor Polski” Official Journal of the Republic of Poland by the President of the Central Statistical Office, or the right to damages.

VIII. Personal data 1. Confidentiality is intended to guarantee that a Whistleblower can feel safe and to minimise the risk of retaliation or reprisals. A Whistleblower who has made a report through an Internal Reporting channel and whose Personal Data have been disclosed without authorisation should promptly notify an impartial internal organisational unit authorised to carry out follow-up activities. The impartial internal organisational unit authorised to carry out follow-up activities shall take action to protect the Whistleblower. 2. The Whistleblower’s identity and all personally identifiable information shall not be disclosed to the persons concerned as part Internal Reporting, to third parties or to other workers and associates of the person concerned. The Whistleblower’s identity and other personally identifiable information may only be disclosed where such disclosure is a necessary and proportionate obligation under generally applicable law in the context of investigations conducted by national authorities. The identity of persons concerned shall be kept confidential to the same extent as the Whistleblower’s identity.

IX. Final provisions 1. In matters not regulated herein, the generally applicable provisions of Polish and European Union law, in particular the Act, shall apply. 2. The procedure shall take effect as of September 18, 2024.