Whistleblowing (Speak-Up) Policy

Our commitment

Kursi Group wants to hear about anything that is unsafe, unethical or illegal. Raising a concern early lets us put things right. We encourage everyone to speak up, and we do not tolerate retaliation against anyone who raises a concern in good faith.

This policy reflects good practice under the Nigerian Code of Corporate Governance 2018, the Federal Government's whistleblowing framework, and international standards such as ISO 37002.

Who can use this policy

Employees, directors, contractors, consultants, suppliers, customers, members of host communities and any other person may raise a concern about Kursi Group Limited, its subsidiaries, or anyone acting on their behalf.

What to report

You should report any genuine concern about, for example:

• bribery, corruption, fraud, theft or money laundering;
• illegal mining, false declarations of mineral origin, or evasion of royalties and taxes;
• dangers to health or safety, or damage to the environment;
• child labour, forced labour or other human-rights abuses, including by security providers;
• harassment, discrimination or abuse of authority;
• misuse of personal data or confidential information;
• breaches of our Code of Business Conduct, policies or the law; and
• any attempt to conceal any of the above.

Personal grievances about your own employment terms should normally go through the HR grievance procedure, unless they involve a wider wrongdoing.

How to report

You can report:

• online through our speak-up form, which allows anonymous reports;
• by email to speakup@kursigroup.com; or
• to your manager, Legal & Compliance, or Internal Control & Audit.

If you believe senior management may be involved, you may report directly to the Chair of the Board's Audit Committee through the same channels, marking your report for their attention.

You are not expected to have proof — only a reasonable belief that something is wrong. Please do not investigate the matter yourself.

Confidentiality and anonymity

We keep the identity of anyone who reports confidential and share it only with those who need to know to investigate, or where the law requires. You may report anonymously; if you do, keep the reference number you receive so that you can provide more information or ask for an update. Anonymous reports can be harder to investigate, so please give as much detail as you can.

Protection from retaliation

No one will suffer dismissal, demotion, harassment, loss of business or any other detriment for raising a concern in good faith, even if it turns out to be mistaken. Anyone who retaliates against a whistleblower will face disciplinary action. Deliberately making a false and malicious report is itself a disciplinary matter.

How we handle reports

1. Acknowledgement. We acknowledge reports within five working days where we have a way to contact you.
2. Assessment. A restricted team independent of the people concerned assesses the report and decides how it should be investigated.
3. Investigation. Investigations are carried out fairly, promptly and confidentially, respecting the rights of everyone involved, including those accused.
4. Outcome. Where possible we tell you that the matter has been concluded, although confidentiality may limit what we can share.
5. Action. Where wrongdoing is found, we take appropriate corrective and disciplinary action and, where required, report to the authorities.

Data protection

Personal data in reports is processed in line with the Nigeria Data Protection Act 2023 and our Privacy Policy. Anonymous reports made online are not linked to your name, contact details or IP address.

External reporting

Nothing in this policy prevents you from reporting to a regulator or law enforcement agency where you are entitled to do so.

Oversight

The Audit Committee oversees this policy, receives regular reports on concerns raised and their outcomes, and reviews the policy at least every two years.