Whistleblowing Policy and Procedure

Introduction

The Investment and Securities Act (Section 306) gives employees of a public company the right to disclose any information about workplace activities that show a criminal offence has been, is being, or is likely to be committed, or where someone has failed or is likely to fail to comply with their legal obligations.

In compliance with this provision, and in line with global best practice, Lasaco Assurance Plc and its subsidiaries are committed to the highest standards of openness, probity, and accountability.

Objective

This policy encourages staff and stakeholders to report perceived unethical or illegal conduct in a confidential manner without fear of harassment, intimidation, victimisation, or reprisal.

Specific objectives are to:

• Provide safe and confidential avenues to raise concerns.

• Ensure employees feel supported in speaking up.

• Encourage improper behaviour to be identified and addressed.

• Deter misconduct that could damage the Company’s reputation.

• Provide clear procedures for reporting and handling concerns.

• Ensure all reports are taken seriously and treated as confidential.

• Promote accountability, transparency, and individual responsibility.

• Foster a culture of openness, accountability, and integrity.

Scope

This policy applies to:

• Employees, Managers, and Executive Management

• Contract staff and third-party personnel

• Business partners in all LASACO locations

Concerns covered include:

• Crimes

• Fraud, theft, bribery, corruption

• Contravention of Company policies

• Corporate governance breaches

• Abuse of office

• Compromise of health, safety, or environment

• Sexual or physical abuse

• Improper conduct or unethical behaviour

• Concealment of any of the above

Board and Management Commitment

The Board and Management are fully committed to creating an environment where concerns can be raised openly, investigated fairly, and resolved without fear of retaliation.

Policy Statement

Lasaco assurance plc encourages whistleblowing in good faith as a way to uphold integrity, transparency, and accountability in all operations. All reports will be investigated, and necessary action taken to protect the Company, its employees, and its stakeholders.

Whistleblowing Procedure

How to raise a concern:

• First with your supervisor or manager.

• If inappropriate, report directly to the Chief Compliance Officer/Company Secretary.

• Reports should include:

  • Background and history of the concern (with dates, if possible)

  • Reasons for concern

Submission channels:

• Hotline

• Email: whistleblowing@lasacoassurance.com

Response time: Within 5 working days, the Compliance Office will:

• Acknowledge receipt

• Indicate how the matter will be handled

• Provide an estimated timeline

• Inform if enquiries have been made

• Confirm whether further investigation will take place

Regulatory reporting: Whistleblowers may also report directly to NAICOM, SEC, NSE, or PENCOM.

Protection of Whistleblowers

• Safety: No loss of job or reprisal for genuine concerns.

• Confidentiality: Identity will be protected unless disclosure is legally required.

• Anonymity: Anonymous reports are accepted, though detailed reports are encouraged.

• Malicious accusations: Strictly prohibited and subject to sanction.

• Retaliation: Treated as a serious offence and subject to disciplinary action.

• Untrue allegations: If made in good faith, no penalty applies even if the concern is not proven.

Responsibility

The Chief Compliance Officer/Company Secretary & Legal Adviser is responsible for:

• Overseeing the policy’s operation and implementation

• Keeping records of all concerns raised

• Monitoring the outcome of investigations