1. Objective

Foremost is based on the premise that all companies within the group and their employees, including directors and executives, must always act in accordance with the core values and Business Principles. This entails acting responsibly, with integrity, and in compliance with Foremost’s policies and procedures, as well as applicable laws and regulations. We expect our employees to contribute to upholding Foremost’s excellent reputation by respecting the high standards reflected in our core values: knowledge, service, trust, simultaneous pursuit of interests, and striving for perfection. Foremost promotes a culture of transparency and accountability, encouraging all stakeholders to report any incidents that violate our core values and/or Business Principles. Any such reports should be made in accordance with the Misconduct Reporting Procedures.

2. Our Procedures

2.1 Introduction
To facilitate the reporting of misconduct within the Foremost Group, a channel has been established through which stakeholders can raise their concerns. All concerns raised in accordance with the official procedures will be treated confidentially (except when a proper investigation is required, including the right of response from the accused) and appropriate actions will be taken as necessary. We ensure that no retaliation will be taken against any employee who makes a report in good faith. The Reporting Line can be used to report suspected or proven serious misconduct within the Foremost Group. This includes, but is not limited to, cases such as:

• Violations of human rights principles
• Health or safety issues
• Violations of Foremost’s Business Principles
• Violations of Foremost’s policies or procedures (e.g., anticompetitive practices, discrimination, harassment, bribery, fraud)
• Criminal offenses
• Non-compliance with legal or regulatory obligations (including improper financial and accounting practices)
• Personal misconduct or disrespectful behavior

The management of Foremost is responsible for the misconduct reporting procedures and their implementation. The management of the Foremost Group has an obligation to ensure the implementation of this Misconduct Reporting Procedure throughout the organization.

2.2 Reporting

Any individual who suspects or witnesses misconduct is obligated to report it. Stakeholders are encouraged to raise their concerns through the normal local reporting channels. Direct communication with management is the fastest, preferred, and most effective means of maintaining a pleasant and transparent working environment throughout the Foremost Group. Reports can be submitted in the local language through the Reporting Line, which consists of a secure web page. To prevent unreliable or false reports and to protect privacy, Foremost will only investigate anonymous reports received through the Reporting Line.

Foremost may decide not to investigate a report if:

• There is insufficient information for a fair investigation and further information cannot be obtained.
• There is an indication that the report was made in bad faith.

After the investigation, immediate and corrective measures will be taken based on the decision of the Management, taking into consideration the relevant functions within the company (e.g., Human Resources and Legal Department). Foremost expects Management at all levels to treat all reports with confidentiality and ensure a prompt response to avoid retaliation. Management is obligated to cooperate with any alleged misconduct investigation.

2.3 Reports in Good Faith or Bad Faith

No person raising a concern in good faith will be harmed as a result. If, after the investigation, no violation is found, no action will be taken against the reporter unless the concern was raised in bad faith. Reports made in bad faith occur when the reporter knows that the report is false and misuses this procedure for personal reasons, self-benefit, or with the intention to deliberately harm Foremost or any employee, including directors. The Foremost Group considers reports made in bad faith as a violation of Business Principles and may take appropriate measures against any reporter who knows that they are making false allegations with malicious intent, including disciplinary action that may result in termination.

2.4 Protection Against Retaliation, Rights, and Duties of the Reporter

The identity of all reporters will be kept confidential if possible, and no retaliation against good-faith reporters will be tolerated. Specifically, the Foremost Group will not dismiss, demote, suspend, threaten, harass, or discriminate against any employee who makes a good-faith report of misconduct. Making a report does not automatically protect reporters who have participated in the report from facing disciplinary actions or any actions related to their participation in the report of misconduct. However, the Foremost Group will consider the fact that the reporter filed a report as a mitigating factor. When reporting a suspicion or case of misconduct, the reporter must continue to fulfill all contractual and confidentiality obligations with the Foremost Group. Therefore, the reporter should refrain from any form of external or internal disclosure without first resorting to internal procedures unless external reporting or other procedures authorized by applicable law are necessary. Foremost reserves the right to take action regarding any breach of these contractual or confidentiality obligations.

If a reporter decides to report misconduct externally while an internal investigation by Foremost is underway, the company may decide not to involve the reporter in the investigation or may terminate the investigation and take necessary measures.

2.5 Protection and Rights of the Accused

When a person is subject to investigation due to a report made through this procedure, they will be notified within a reasonable time, depending on the facts and circumstances, and if there is a risk of destruction of evidence, retaliation, and/or obstruction of the investigation. Any person under investigation has the right to respond to the allegations and can appeal against any findings or decisions made.

2.6 Data Protection, Privacy, and Confidentiality

Any personal information obtained as part of a report or investigation under this procedure (from the reporter, any person under investigation, and any witnesses) will only be used for the purposes described in this procedure and in accordance with data protection laws and Foremost’s data protection policy. Personal information will only be shared with necessary individuals and will be subject to confidentiality obligations, to the extent possible and consistent with the need to conduct an investigation and, if necessary, take actions. There may be exceptions when Foremost has a legal or regulatory obligation to disclose the information or if the report is made in bad faith.

2.7 Amendments

The Foremost Management may amend this policy at any time in accordance with the needs of applicable laws and regulations.