Our Commitment to Transparency and Integrity

‍At MAX, we are committed to maintaining the highest standards of ethical conduct, transparency, and accountability. We believe that fostering an open working environment where concerns about misconduct can be raised without fear is essential to our integrity and success.

This Whistle-Blowing Policy establishes a safe and confidential channel for employees and stakeholders to report suspected serious misconduct, ensuring that all concerns are investigated thoroughly and addressed appropriately.

Policy Purpose

The objectives of this Whistle-Blowing Policy are to:

•  Provide accessible channels for reporting concerns about workplace malpractice and misconduct.
•  Encourage timely reporting of suspected violations and unethical behavior.
•  Protect whistle-blowers from retaliation, intimidation, or unfair treatment when reporting concerns in good faith.
•  Demonstrate accountability by investigating all reports seriously and taking appropriate corrective action.
•  Foster a culture of transparency, integrity, and ethical business practices across all MAX operations.

Scope of the Policy

This policy applies to all MAX employees, regardless of grade, position, location, or function, as well as to other stakeholders including contractors, vendors, service providers, and business partners.

What Can Be Reported

This policy covers serious concerns about workplace misconduct, including but not limited to:
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•  Fraud, corruption, bribery, or theft involving company resources or business transactions.
•  Improper conduct or unethical behavior that undermines core ethical values such as integrity, respect, accountability, and fairness.
•  Abuse of authority or misuse of position for personal gain or to harm others.
‍•  Failure to comply with MAX policies, procedures, or legal requirements.
•  Sexual or physical abuse of any employee, contractor, vendor, or stakeholder
•  Gross misuse of company assets or resources, or gross waste.
• Attempts to conceal any of the above-listed acts or to prevent their disclosure. that undermines core ethical values such as integrity, respect, accountability, and fairness.

Who Is a Whistle-Blower?

A whistle-blower is any person who reports suspected improper or illegal activities in good faith. Whistle-blowers may be:

  •  MAX employees at any level
  •  Job applicants
  •  Contractors and vendors
  •  Business partners
  •  Other stakeholders with knowledge of misconduct

Important: A whistle-blower's role is to report concerns, not to investigate them. MAX's designated personnel will conduct investigations and determine appropriate actions.

Good Faith Reporting

MAX expects all reports to be made in good faith. This means:

  •  The report is made without malicious intent or consideration of personal benefit
  •  The whistle-blower has a reasonable basis to believe the information is true
  •  The report is not knowingly false or fabricated
 
You do not need proof: A concern does not have to be proven to be true to be reported in good faith. We encourage you to report suspicions even if you are uncertain, as long as you have reasonable grounds for your concern.

False or malicious reports: Any individual who knowingly makes a false claim or reports with malicious intent will be subject to appropriate disciplinary action.

Protection for Whistle-Blowers

MAX is committed to protecting individuals who report concerns in good faith from any form of retaliation.

No Retaliation Policy

Whistle-blowers will not be subjected to:

  •  Harassment or intimidation
  •  Victimization or discrimination
  •  Adverse employment actions (dismissal, demotion, suspension, denial of promotion)
  •  Threats or any other form of retaliationAny person who retaliates against a whistle-blower will face serious disciplinary action, up to and including termination of employment.

Confidentiality
MAX respects the confidentiality of whistle-blowers and will protect their identity to the fullest extent possible. Your identity will not be disclosed without your consent, except where:

  •  Disclosure is required by law
  •  Victimization or discrimination
  •  Disclosure is necessary for a proper investigation
  
We understand that some individuals may prefer to remain anonymous, and we accept anonymous reports. However, we encourage whistle-blowers to identify themselves when possible, as this can facilitate more effective investigation and follow-up.

If Your Concern Is Not Confirmed

If an allegation is made in good faith but subsequent investigation does not confirm wrongdoing, no action will be taken against the person who made the report. You will not face any negative consequences for raising a genuine concern that turns out to be unsubstantiated.

How To Report Your Concern

MAX provides multiple channels for reporting concerns to ensure accessibility and comfort for all whistle-blowers. You may report through any of the following methods:

Reporting Channels

1. Physical Suggestion Box
     ○    Drop a written note in the suggestion box located at MAX offices
‍2. Email Reporting
     ○   Send an email (anonymously if preferred) to: safeguarding@maxdrive.ai
     ○   This email is monitored by a member of the Board, the Head of People, and the company's external legal counsel
3. Phone or Text Message
    ○    Call or send a text message to: +234 817 223 5672

What information to include
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When making a report, please provide as much detail as possible, including:

  •  Description of the suspected misconduct
  •   Names of individuals involved (if known)Dates, times, and locations of incidents
  •   Any witnesses to the conduct
  •   Relevant documents or evidence (if available)
  •   Any other information that may assist in the investigation
  
The more information you can provide, the more effectively we can investigate your concern. However, do not let lack of complete information prevent you from reporting—report what you know.

Investigation Process

‍All reports of suspected misconduct will be taken seriously and investigated promptly and thoroughly.

What Happens After You Report

1. Acknowledgment: Your report will be acknowledged (if you have provided contact information)
2. Preliminary Assessment: The report will be reviewed to determine the appropriate investigation approach
‍3. Investigation: A thorough, impartial investigation will be conducted by appropriate personnel
‍4. Action: If wrongdoing is confirmed, appropriate corrective and disciplinary action will be taken
‍5. Follow-up: Where possible, you will be informed of the outcome (subject to confidentiality requirements)

Independence and Impartiality

Investigations will be conducted by individuals who have no involvement in the matter being investigated and who can assess the situation objectively.

Policy Review and Updates

‍This policy is reviewed periodically to ensure it remains effective and aligned with best practices and regulatory requirements. Suggestions for improvements can be submitted to the Human Resources or Legal Department.

Additional Support

If You Need Guidance

‍If you are unsure whether a matter should be reported under this policy, or if you need assistance with making a report, you may contact:

External Reporting

‍While MAX encourages internal reporting to allow us to address concerns directly, we recognize that in some circumstances, you may feel it necessary to report concerns to external authorities. You have the right to do so in accordance with applicable laws, and MAX respects this right.

Our Commitment to You

‍MAX values the courage it takes to speak up about wrongdoing. We are committed to:

   • Listening to your concerns with respect and taking them seriously
   • Acting promptly and decisively to investigate reports
   • Protecting you from any form of retaliation
   • Learning from concerns raised to improve our operations and culture
   • Maintaining the highest standards of business ethics and integrity

Your voice matters in maintaining the integrity and reputation of MAX. By reporting concerns, you help us maintain the trust of our stakeholders and ensure we continue to operate ethically across all our markets.

Contact Information
‍
‍For questions about this policy or to make a report:

   • Email: safeguarding@maxdrive.ai
   • Phone/Text: +234 817 223 5672

Remember: Speaking up about wrongdoing is the right thing to do. MAX is committed to protecting and supporting you when you report concerns in good faith.