Slice Financial Whistleblowing Policy

1. Definitions

• Qualifying Disclosure: A disclosure of information made in good faith that relates to a reasonable suspicion that Slice Financial, or any of its employees, officers, or third-party partners, has or may have: i) Contravened a provision of any applicable law or regulatory framework administered by governing authorities, including but not limited to the Virtual Assets Regulatory Authority (VARA), the Dubai Financial Services Authority (DFSA), the SEC (USA), or MiFID/MICA (Europe); or ii) Engaged in money laundering, fraud, market manipulation, or any other financial crime.

• Staff / “You” / “Your”: All Slice Financial directors, officers, agents, employees, temporary workers, interns, consultants, and contractors, as well as vendors acting for or on behalf of Slice Financial, regardless of the duration of their relationship or contract.

• Slice Financial / “The Company” / “We” / “Our”: All corporate entities, including our Delaware headquarters, Slice Gmbh (Europe), and our Middle East subsidiaries, over which Slice Financial exercises control regarding policies and procedures.

2. Purpose Slice Financial is committed to maintaining the highest standards of transparency, integrity, and accountability in bridging traditional finance and decentralized finance. To support this, we have established a robust whistleblower framework designed to encourage a “speak-up” culture and protect those who report misconduct.

The primary objective of this policy is to ensure that no whistleblower, by reason of making a Qualifying Disclosure, shall:

• Be subject to civil, criminal, or contractual liability;

• Have any contractual, civil, or other remedy or right enforced against them by another person; or

• Be dismissed from their current employment, demoted, harassed, or otherwise subject to any retaliatory action by the Company or its related parties that is reasonably likely to cause them detriment.

3. Scope This policy applies globally to all Staff at all levels, including third-party vendors, vault operators, and technology partners associated with Slice Financial.

4. Compliance Officer’s Role and Responsibilities The Chief Compliance Officer (CCO) is primarily responsible for:

• Overseeing the management, implementation, and strict adherence to this policy globally.

• Referring concerns to, or seeking assistance from, specialized departments (e.g., Legal, IT Security, or Asset Management) during investigations, ensuring adherence to internal guidelines.

• Communicating directly and securely with relevant employees and third parties who have raised concerns within the scope of this policy.

• Monitoring the security and efficacy of reporting channels, ensuring absolute confidentiality and compliance with data record-keeping obligations.

• Managing and maintaining independent oversight of all internal and external investigations.

5. Qualifying Disclosures A Qualifying Disclosure occurs when a report is made in good faith regarding an entity, employee, or officer suspected of:

• Contravening applicable laws administered by regulatory bodies (e.g., VARA, SEC, DFSA).

• Engaging in money laundering, fraud, bribery, theft, or other financial crimes.

5.1 Examples of Misconduct

• 5.1.1 Fraud: Fraud encompasses a wide range of misconduct, including theft (of either digital tokens or physical Reserve Assets), corruption, embezzlement, bribery, forgery, misrepresentation, collusion, and concealment of material facts. It involves the use of deception for personal or third-party gain, or to cause a loss to another. Fraud not only has severe financial impacts but can critically damage the reputation of an organization entrusted with managing Real World Assets (RWAs) and investor funds.

• 5.1.2 Money Laundering: The illegal process of making large amounts of money (or Virtual Assets) generated by criminal activity appear to have come from a legitimate source. This includes attempting to use Slice Financial’s tokenization or exchange platforms to “clean” illicit fiat or cryptocurrency.

6. Protection of the Whistleblower We are fully dedicated to safeguarding whistleblowers and ensuring their absolute confidentiality. Disclosures will be handled based on specific, credible information without breaching our ethical standards.

A whistleblower is guaranteed the following protections:

• Confidentiality: Strict non-disclosure of any information concerning their identity and whereabouts.

• Immunity: No whistleblower will be considered to have violated non-disclosure agreements or confidentiality clauses related to the entity for which they work, provided the disclosure is made in good faith and is not maliciously false.

• Protection from Retaliation: Whistleblowers are explicitly protected against revenge, harassment, demotion, prosecution by other employees, or any bias (internal or external) affecting their current or future standing.

7. Reporting Concerns Concerns regarding actual or suspected wrongdoing should be raised via our confidential reporting channels.

• Direct Reporting: Reports should be sent directly to our Chief Compliance Officer via secure email: compliance@slicefinancial.ai.

• Line Management: Employees may initially raise concerns in writing with their direct line manager. If an employee is uncomfortable reporting to their direct manager, they may report to an alternative manager or the HR Department. The receiving manager must immediately refer the matter to the CCO.

7.1 Recordkeeping and Anonymity

• Recordkeeping: We maintain a secure, encrypted log of all disclosures and whistleblowing details. We will conduct a prompt investigation into all credible concerns.

• Providing Detail: When submitting a report, please provide as much detail as possible (e.g., names, dates, transaction hashes, asset locations) to facilitate a thorough fact-finding process.

• Anonymity: We recognize that whistleblowers may not always feel comfortable identifying themselves. Reports may be submitted anonymously. However, please note that anonymous reports may limit our ability to conduct a comprehensive investigation.

• False Reports: If an investigation determines that a knowingly false report was made maliciously or for personal gain, the reporter will be subject to disciplinary action, up to and including immediate termination of employment.

8. Investigation Process Upon receipt of a disclosure, the CCO will evaluate whether the concern falls within the scope of this policy, assess its severity, and determine the necessary investigative steps.

• Appointed investigators will be strictly independent and completely detached from any teams related to the subject matter of the report.

• In highly sensitive or serious cases (such as those involving smart contract exploits or third-party vault breaches), investigations may be conducted by independent external legal counsel, forensic auditors, and relevant regulatory authorities.

• We commit to the fair and objective treatment of all individuals involved in an investigation, including those under suspicion.

8.1 Filing to Authorities If the internal investigation and subsequent legal counsel review yield evidence of criminal activity, Slice Financial will adhere to all applicable laws and mandatory reporting procedures, including filing formal reports with the relevant local and international authorities (e.g., UAE Law Enforcement, VARA, SEC).

8.2 Violations of this Policy Any employee found to have violated this policy—particularly by retaliating against a whistleblower or breaching confidentiality—will face severe disciplinary action in accordance with relevant employment laws in their operating jurisdiction.