Whistleblowing Policy

528 Productions

1. Legal Framework

This Whistleblowing Policy (hereinafter the “Policy”) has been adopted in accordance with the Law of 28 November 2022 on the protection of persons who report breaches of Union or national law within private legal entities.

528 Productions confirms its commitment to conducting its activities in compliance with applicable legislation, ethical standards, and principles of good governance.

2. Purpose of the Policy

This Policy aims to:

• define the conditions under which reports may be made
• determine the material and personal scope
• describe the internal reporting procedure
• ensure confidentiality and protection against retaliation
• regulate the processing and retention of personal data

This Policy does not affect existing statutory reporting or complaint mechanisms.

3. Publication and Accessibility

This Policy is available:

• via the 528 Productions website
• via the company’s internal communication channels

4. Scope

4.1 Material Scope

This Policy applies to reports concerning information about breaches, including:

• violations of Union or national legislation
• fraud, corruption, or bribery
• tax or financial violations
• social and labour law violations
• consumer protection
• data protection and privacy
• environmental, health, and safety legislation
• other legal or regulatory violations

“Information about breaches” means information, including reasonable suspicions, regarding actual or potential breaches.

4.2 Personal Scope

This Policy applies to the following reporting persons:

• employees and former employees
• applicants
• self-employed collaborators, consultants, and freelancers
• interns
• directors
• suppliers, subcontractors, and their employees
• any person professionally connected with 528 Productions

5. Reporting Conditions

Protection under this Policy applies only if:

• the reporting person acts in good faith
• the reporting person had reasonable grounds to believe that the reported information was accurate at the time of reporting
• the report falls within the scope of the law and this Policy

Reports made maliciously, abusively, or based on knowingly false information may result in appropriate measures, including civil and criminal liability.

6. Reporting Channels

6.1 Internal Reports

Reports may be made via:

Email: whistleblowing@528.co

6.2 Receipt and Follow-up

Upon receipt of a report:

• acknowledgment of receipt will be provided within 7 calendar days
• additional information may be requested
• feedback will be provided within a maximum period of 3 months

Follow-up means any action taken to verify, assess, and, where appropriate, remediate the reported breach.

6.3 External Reports

Reporting persons retain the right to submit reports through the legally designated external reporting channels, including:

Federal Ombudsman
Leuvenseweg 48 box 6
1000 Brussels
Belgium

6.4 Public Disclosure

Public disclosure is permitted only under the conditions set out in the Law of 28 November 2022.

7. Confidentiality

528 Productions guarantees:

• the confidentiality of the reporting person’s identity
• the confidentiality of any information that may directly or indirectly lead to identification
• restricted access to reporting information

Disclosure of identity is permitted only:

• with the reporting person’s explicit consent
• where legally required

8. Protection Against Retaliation

528 Productions prohibits any form of retaliation against reporting persons protected under this Policy.

Retaliation includes, but is not limited to:

• dismissal
• demotion
• intimidation
• discrimination
• adverse treatment

9. Processing of Personal Data

528 Productions acts as the data controller within the meaning of the General Data Protection Regulation (GDPR).

Personal data is processed:

• solely for purposes related to the handling of reports
• with appropriate technical and organisational security measures
• in compliance with applicable regulations

Data protection contact: privacy@528.co

10. Retention of Reports

528 Productions maintains a confidential register.

Reports and related data are retained:

• for as long as necessary for follow-up and legal obligations
• in compliance with confidentiality and data protection requirements

11. Governing Law

This Policy is governed by and interpreted in accordance with Belgian law.

12. Amendments to the Policy

528 Productions reserves the right to amend this Policy.

Amendments will be published via the usual communication channels.

13. Entry into Force

This Policy enters into force on 01/02/2026 and applies for an indefinite duration.