Mainstreet Capital Limited.

1. Policy Statement

Mainstreet Capital Limited is committed to conducting its business with the highest standards of integrity, transparency, accountability, and ethical behaviour. The Company recognizes the importance of providing a secure and confidential avenue through which employees, directors, contractors, consultants, clients, and other stakeholders may raise concerns regarding actual or suspected misconduct.

This Policy encourages the reporting of genuine concerns relating to unethical, illegal, or improper conduct and ensures that such concerns are investigated appropriately and without fear of retaliation.

2. Purpose

The purpose of this Policy is to:

• Promote a culture of honesty, accountability, and ethical conduct.
• Encourage the timely reporting of suspected wrongdoing.
• Provide a framework for the confidential disclosure of concerns.
• Ensure that reported concerns are reviewed and investigated fairly and objectively.
• Protect individuals who report concerns in good faith from retaliation or victimization.
• Support compliance with applicable laws, regulations, and corporate governance requirements.

3. Scope

This Policy applies to all persons associated with Mainstreet Capital Limited, including:

• Directors
• Employees
• Consultants
• Contractors
• Vendors and suppliers
• Clients and customers
• Shareholders
• Any other stakeholder interacting with the Company

4. Reportable Concerns

Concerns that may be reported under this Policy include, but are not limited to:

• Fraud, theft, or financial irregularities
• Bribery, corruption, or improper payments
• Money laundering or other financial crimes
• Breaches of laws, regulations, or internal policies
• Abuse of authority or misuse of company resources
• Conflicts of interest
• Harassment, discrimination, or workplace misconduct
• Health, safety, or environmental violations
• Deliberate concealment of wrongdoing
• Any conduct that may damage the Company’s reputation or compromise its ethical standards

5. Confidentiality

Mainstreet Capital Limited is committed to protecting the identity of individuals who raise concerns under this Policy. All disclosures will be handled with the highest level of confidentiality possible, consistent with the need to conduct a thorough investigation and comply with legal and regulatory obligations.

Information relating to a report will only be shared with individuals who have a legitimate need to know in the course of assessing or investigating the matter.

6. Protection Against Retaliation

The Company strictly prohibits any form of retaliation against an individual who reports a concern in good faith or participates in an investigation.

Retaliation may include:

• Dismissal or termination of employment
• Demotion or denial of promotion opportunities
• Harassment or intimidation
• Unfair treatment or discrimination
• Any other adverse action arising from the disclosure

Any person found to have engaged in retaliatory conduct will be subject to appropriate disciplinary action.

7. Investigation Process

All concerns raised under this Policy will be assessed promptly and, where appropriate, investigated in a fair, independent, and objective manner.

The Company will:

• Review all reports received.
• Conduct a preliminary assessment of the matter.
• Initiate an investigation where necessary.
• Take appropriate corrective or disciplinary action where wrongdoing is established.
• Escalate matters to relevant regulatory or law enforcement authorities where required by law.

The nature and extent of any investigation will depend on the circumstances of the reported concern.

8. False or Malicious Reports

Individuals are expected to make disclosures honestly and in good faith.

Any person who knowingly submits false, malicious, or misleading allegations may be subject to disciplinary action and, where applicable, legal proceedings.

9. Record Keeping

The Company shall maintain appropriate records of all whistleblowing reports, investigations, findings, and actions taken, in accordance with applicable legal, regulatory, and record-retention requirements.

10. Policy Review

This Policy shall be reviewed periodically to ensure its continued effectiveness and alignment with applicable laws, regulations, industry standards, and corporate governance best practices.

Contact Information

For enquiries or to report concerns under this Policy, please contact:

Mainstreet Capital Limited

Plot 954A, Idejo Street, Off Adeola Odeku Street
Victoria Island, P.M.B. 12809
Lagos, Nigeria

Telephone: 02012296722

Email: whistleblowing@mainstreetcapltd.com

Website: www.mainstreetcapltd.com