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RYPLEX SOLUTIONS LTD.

Ethics Reporting and Whistleblower Protection Policy

The procedure for reporting suspected misconduct, regulatory breaches, or unethical behaviour, and how persons making reports are protected from retaliation.
  • Corporate Number: 1001543287
  • Registered Office: 1110 Finch Avenue West, Unit 1293, North York, Ontario, M3J2T2,

1. Policy Statement

Ryplex Solutions Ltd. (“Ryplex”, “Company”, “we”, “our”, or “us”) is committed to maintaining a business environment based on lawful conduct, integrity, accountability, and responsible corporate governance.
This Policy sets out the procedure for reporting suspected misconduct, regulatory breaches, unethical behaviour, financial crime concerns, or serious violations of Company rules. It also explains how such reports are reviewed and how persons making reports are protected from retaliation.
The purpose of this Policy is to ensure that concerns are raised early, reviewed fairly, and addressed through an appropriate internal process.

2. Application of this Policy

This Policy applies to persons who have a professional, contractual, corporate, or business-related connection with Ryplex Solutions Ltd., including:
  • employees, whether full-time, part-time, temporary, or probationary;
  • directors, officers, managers, and authorised representatives;
  • shareholders, investors, and beneficial owners, where applicable;
  • contractors, consultants, outsourced service providers, and business partners;
  • former personnel, where the concern relates to information obtained during their relationship with the Company;
  • any other person who becomes aware of serious misconduct connected with the Company's operations.
Reports may be made regardless of seniority, role, or length of relationship with the Company.

3. Matters That May Be Reported

A report may concern any suspected, actual, or attempted misconduct involving Ryplex Solutions Ltd., its personnel, customers, counterparties, or service providers.
Reportable concerns may include, without limitation:
  • fraud, theft, embezzlement, forgery, or misuse of Company assets;
  • bribery, corruption, kickbacks, conflicts of interest, or improper benefits;
  • money laundering, terrorist financing, sanctions evasion, or other financial crime risks;
  • serious breaches of AML, CTF, sanctions, fraud prevention, or reporting obligations;
  • manipulation of records, accounts, customer files, transaction data, or compliance reports;
  • deliberate failure to follow internal policies or regulatory requirements;
  • misuse of confidential information or personal data;
  • harassment, discrimination, retaliation, or serious workplace misconduct;
  • gross negligence, abuse of authority, or serious operational mismanagement;
  • concealment of any of the above.
This Policy is not intended to replace ordinary HR, support, or customer complaint procedures unless the matter involves serious misconduct or public-interest concerns.

4. Legal and Compliance Context

Ryplex Solutions Ltd. maintains this Policy with reference to applicable Canadian legal, regulatory, employment, financial crime, and corporate governance requirements.
Relevant areas may include:
  • Canadian criminal law concerning fraud, bribery, corruption, money laundering, and terrorist financing;
  • anti-money laundering and counter-terrorist financing obligations;
  • sanctions compliance and financial crime reporting duties;
  • employment standards and workplace protection rules;
  • privacy and personal information protection requirements;
  • corporate, tax, accounting, and financial services obligations.
The Company may also apply internal standards that are stricter than the minimum legal requirement where necessary to protect the integrity of its operations.

5. Reporting Channels

Email Reporting. Reports may be sent to the Company through its designated compliance or support contact channel.
Written Reporting. Reports may also be submitted in writing to the Company’s registered office:
Ryplex Solutions Ltd., 1110 Finch Avenue West, Unit 1293 North York, Ontario, M3J2T2, Canada

6. Information to Include in a Report

To allow the Company to assess and investigate a concern effectively, a report should, where possible, include:
  • a clear description of the suspected misconduct;
  • names or roles of persons involved;
  • relevant dates, times, locations, systems, accounts, or transactions;
  • copies of documents, screenshots, emails, records, or other evidence;
  • details of any witnesses;
  • whether the matter has already been reported elsewhere;
  • preferred method of contact, if the whistleblower wishes to be contacted.
A report does not need to be legally proven at the time of submission. However, it should be made honestly and based on reasonable belief.

7. Anonymous Reports

Ryplex Solutions Ltd. may accept anonymous reports where permitted by law and operationally possible.
Anonymous reporting can help protect the identity of the person raising the concern, but it may also limit the Company’s ability to:
  • request clarification;
  • verify facts;
  • obtain supporting evidence;
  • provide updates;
  • complete a full investigation.
Where anonymity is requested, the Company will make reasonable efforts to respect it, subject to legal, regulatory, and investigative requirements.

8. Confidentiality

Reports will be handled confidentially to the extent reasonably possible.
Information relating to a whistleblowing report may be shared only with persons who need access for review, investigation, legal advice, regulatory reporting, disciplinary action, or remediation.
Confidentiality may be limited where disclosure is required by:
  • law or court order;
  • regulatory authority request;
  • law enforcement inquiry;
  • AML/CTF or sanctions reporting obligations;
  • the need to conduct a fair and effective investigation.

9. Protection Against Retaliation

Ryplex Solutions Ltd. prohibits retaliation against any person who raises a concern in good faith.
Retaliation may include:
  • dismissal or demotion;
  • intimidation, harassment, or threats;
  • reduction of duties or working hours;
  • unfair disciplinary action;
  • unfair disciplinary action;
  • exclusion from opportunities;
  • adverse treatment by colleagues, managers, or representatives.
Any person who retaliates against a whistleblower may be subject to disciplinary action, contractual remedies, or other appropriate measures.

10. Good Faith Requirement

Whistleblowers are expected to make reports honestly and with a reasonable belief that the information may be true.
The Company will not penalise a person for raising a concern in good faith, even if the concern is not ultimately confirmed.
However, knowingly false, malicious, or deliberately misleading reports may result in disciplinary action or other consequences.

11. Review and Investigation Process

After receiving a report, Ryplex Solutions Ltd. may take the following steps:
  • acknowledge receipt where contact details are available;
  • perform an initial assessment of the concern;
  • determine whether the matter falls within this Policy;
  • appoint appropriate personnel or external advisers to review the matter;
  • secure relevant documents, system logs, communications, or transaction data;
  • interview relevant persons where necessary;
  • determine whether corrective, disciplinary, regulatory, or legal action is required.
Investigations will be conducted objectively, proportionately, and with due regard to confidentiality and fairness.

12. Outcomes and Remedial Action

Depending on the findings, the Company may take one or more actions, including:
  • closing the matter where no breach is identified;
  • improving internal controls or procedures;
  • providing training or guidance;
  • correcting inaccurate records;
  • restricting system or account access;
  • taking disciplinary or contractual action;
  • notifying regulators, law enforcement, financial institutions, or other competent authorities where required;
  • implementing remediation measures to reduce future risk.
The Company may be unable to disclose full investigation results where confidentiality, privacy, employment, legal, or regulatory restrictions apply.

13. Recordkeeping

Ryplex Solutions Ltd. will maintain appropriate records of whistleblowing reports, assessments, investigations, evidence reviewed, decisions made, and remedial steps taken.
Records will be retained for a period consistent with legal, regulatory, employment, and operational requirements.
Access to whistleblowing records will be limited to authorised persons with a legitimate need to know.

14. External Reporting

Where permitted or required by law, individuals may have the right to report certain matters to competent external bodies, regulators, law enforcement, or other authorities.
Nothing in this Policy prevents a person from making a protected disclosure to an appropriate authority where such disclosure is lawful.
However, the Company encourages internal reporting first where this is safe, appropriate, and does not interfere with legal obligations or urgent risk prevention.

15. Policy Review

This Policy may be reviewed and updated periodically to reflect changes in law, regulatory expectations, Company structure, operational risks, or internal governance arrangements.
Updated versions will become effective once approved and published or otherwise communicated by the Company.
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