BioAgilytix Ethics and Compliance Helpline

At BioAgilytix, we are committed to conducting all aspects of our business in an ethical and transparent way. We deliver this through our unwavering commitment to comply with all applicable local laws, regulations, guidelines, industry standards, and codes of conduct in the countries where we operate. Our new Ethics and Compliance Helpline allows employees to report possible misconduct any time they see or become aware of a suspected violation of company policies, procedures, regulations, or unethical or illegal behavior.

Q. What is the Ethics and Compliance Helpline?

An efficient and trusted mechanism, hosted by a third-party vendor, Ethico/MyComplianceLine, by which employees can anonymously and confidentially report allegations of suspected or actual misconduct.

Q. Who maintains/monitors the Ethics and Compliance Helpline?

BioAgilytix's Ethics and Compliance Helpline is managed by Ethico/MyComplianceLine, a third-party vendor, that specializes in compliance and ethics reporting.

Q. Is my information secure?

Ethico/MyComplianceReport utilizes the latest 128-bit encryption technology. No data mining or off-site web hosting is used. All your report information is kept in their highly secure facility.

Q. How can I make a report?

Employees can make reports in two different ways, and both offer the same level of confidentiality:

• 1) Call the Helpline: each country where we have sites has its own unique phone number:
  US: 888-866-6324
  Germany: 0800 1811283
  Australia: 1800 221 235
• 2) Visit the Web Portal: https://www.bioagilytix-icare.com/ to file a web-based report.

Every report is given a reference number and you will be able to track your report on either the web portal or by calling the helpline.

Q. When can I make a report?

The phone and the web portal are available 24 hours a day, 365 days a year to allow parties to report misconduct whenever they feel safe and ready to do so.

Q. What information do I need to provide about my complaint?

To facilitate a thorough review, Ethico must receive specific details concerning the matter. Providing partial or incomplete information may result in case closure due to insufficient information. An example of information that may be needed to complete a thorough review may include:

• First/last name of person(s) or organization(s) engaged in the alleged wrongdoing.
• Description of the event, location, and date/time of when the event occurred.
• Specific details or synopsis of the concern(s) being raised.
• First/last names of witnesses to the event or others who may have knowledge of the concern(s) being raised.
• How the event was discovered if the reporter was not a participant or directly involved
• Supporting documentation if available, including policies, memoranda, emails, text messages, etc.

Q. What types of situations should I report through this helpline?

Any questions or concerns regarding actual or potential violations of applicable law, regulation, policy or procedure, or the Code of Conduct (Code) should be reported. Reporters are protected from retaliation for concerns raised in Good Faith (believed to be true). You can report a wide variety of issues through this system including but not limited to:

• Retaliation
• Bribery and Kickbacks
• Fraud
• Conflict of Interest
• Embezzlement or Theft
• Falsification of contract, reports, and records
• Discrimination based on gender, race, disability.
• Health and Safety
• Code of Conduct & Policy violations

Q. Why should I report what I know? What's in it for me?

BioAgilytix team members have an obligation to report unsafe practices, unethical behavior or violations pertaining to the Code of Conduct, policy or procedure, or applicable law or regulation. When someone's actions violate our Code, our policies or procedures, or applicable laws or regulations, it can harm BioAgilytix, our employees and even our clients. If a law is violated, the result could be civil or criminal action against BioAgilytix and the person(s) responsible. We take any potential violation seriously. Reports of potential misconduct are reviewed carefully, and steps are taken to correct the situation, including disciplinary action when appropriate.

Q. If I do not want to use the Helpline, who can I report a concern to?

You are encouraged to notify your manager, senior leadership, or Human Resources to report a concern or questions.

BioAgilytix team members have an obligation to report unsafe practices, unethical behavior or violations pertaining to the Code of Conduct, policy or procedure, or applicable law or regulation. When someone's actions violate our Code, our policies or procedures, or applicable laws or regulations, it can harm BioAgilytix, our employees and even our clients. If a law is violated, the result could be civil or criminal action against BioAgilytix and the person(s) responsible. We take any potential violation seriously. Reports of potential misconduct are reviewed carefully, and steps are taken to correct the situation, including disciplinary action when appropriate.

Q. Do I have to reveal my identity?

You may submit a report regarding serious concerns or violations while remaining anonymous. The only information required for a new report is brief details regarding the concern so we may begin an investigation to determine the validity of the violation.

If you choose to identify yourself, Ethico/MyComplianceLine is under a strict Confidentiality Agreement with BioAgilytix. Identifying yourself allows for better resolution of the issue but it is not required.

Q. Am I protected if I make a report?

BioAgilytix has a zero-retaliation policy. Employees who submit reports in good faith, anonymously or not, are protected from retaliation from their manager and/or colleagues. If you believe that you or another colleague has been retaliated against for reporting a concern or for participating in an investigation, you should contact a member of Human Resources. You may also report any retaliation via this Helpline.

Q. Where do these reports go? Who can access them?

Reports made through the Ethics and Compliance Helpline are collected by Ethico employees and maintained on Ethico's secure servers. These team members are specially trained to handle complex and sensitive matters in a confidential manner. A limited number of employees in the Human Resources Department can access these reports.

Q. How long will the investigation take?

Each allegation reported through the Ethics and Compliance Helpline is unique, so the estimated time of completion depends on many factors, such as the complexity of the issue, the number of people involved, the nature and extent of documents or other evidence involved, and the urgency of the matter.

Q. How do I get updates from investigators? How do I share additional details? How do I know the outcome of my report?

The Ethics and Compliance Helpline assigns a unique identification number to each submitted report. This number allows the reporter to check on the status of a case review or communicate with the lead investigator. On the homepage, click 'Follow-up' to ask questions, provide updates or inquire about the status of the review.

In addition, the employee submitting the report through the webportal will be asked to provide a unique password. The combination of the unique identification number and password allows the reporter to check the status of the report no matter if they provided their name or chose to file the report anonymously. However, if an anonymous reporter wants to call in all they will need the report number and then they will be asked to verify two pieces of information to verify they are the person who made the report.

Q. What if I forgot my report number?

Unfortunately, if you have lost or forgotten your Report Number you will need to begin a New Report. For security and confidentiality reasons, we are not able to retrieve lost Report Number's.

Q. What does "confidentiality" mean? Is it the same as "anonymity?"

Confidentiality means that members of Ethico/MyCompliance Line and the Human Resources Department will not disclose information to individuals outside of the reasonable "need to know" standard. This includes information received, used, maintained, or accessed during normal duties, such as case reviews.

Anonymity (or "anonymous") applies to an individual's identity and means that BioAgilytix team members may report any concern through the Ethics and Compliance Helpline without disclosing their identity. Reports made in Good Faith will be taken and reviewed without an attempt to identify the reporter.
Be advised that:

• There are circumstances in which confidentiality and anonymity may not be maintained, such as disclosures pursuant to a subpoena or court order, a lawful discovery request or a disclosure necessary to resolve a potential compliance matter.
• Reporters may choose to release their identity during or after a completed review.
• Information shared through the Ethics and Compliance Helpline may lead to indirect identification of a reporter given the specific details provided.

Q. Is MyComplianceReport and the ComplianceLine the same thing?

The ComplianceLine is an all-inclusive term and refers to the MyComplianceReport web-based portal as well as the toll-free telephone number. Both are maintained by Ethico.