GRIEVIENCE HANDLING

1.1

Epoch Digital Pte. Ltd. (the “Company”)is committed to maintaining a fair, respectful and inclusive work environment where employees are treated with dignity,professionalism and integrity.

1.2

This Grievance Policy establishes a formal framework for employees toraise workplace concerns and ensures such concerns are addressed promptly,fairly, confidentially and without retaliation.

2.1

“Company” refers to EpochDigital Pte. Ltd., the ultimate holding company of the Epoch Digital Group,and, where applicable, the local employing entity that has entered into anEmployment Agreement with the Employee(including Epoch DC Pte. Ltd. in Singaporeand any other local employing entities within the Group), together with their related corporations,joint venture companies, affiliates, and subsidiaries (collectively, the “Epoch Digital Group”, the “Company”, or “we”).

2.2

This Policy applies to all employees of the Company, includingfull-time, part-time, probationary, fixed-term, secondees and contractemployees across all jurisdictions in which the Epoch Digital Group operates.

2.3

“Management” means authorised individuals of Epoch Digital Group, including Employees of its parent or ultimate holding companies, who have executive decision-making authority.

3.1

 A grievance refers to a work-related concern, dissatisfaction orcomplaint raised by an employee in connection with employment matters,including but not limited to:

• Unfair treatment or perceived inequity
• Workplace harassment, bullying or discrimination
• Conflict with colleagues, supervisors or functional reporting lines
• Breach of Companypolicies or procedures
• Working conditions, health or safety concerns
• Misconduct impacting the employee

3.2

This Policy does not apply to:

• Formal performance management processes
• Disciplinary proceedings
• Matters involving suspectedfraud, corruption, bribery or financialmisconduct

4.1

All grievances will be managed in accordance with the following principles:

• Fairness and impartiality
• Procedural consistency across the Group
• Confidentiality on a strict need-to-know basis
• Timely and proportionate resolution
• Protection against retaliation
• Compliance with applicable local labour laws and data protection regulations

5.1

Informal Resolution(Encouraged First Step)

Employees are encouraged, where appropriate,tofirst attempt informal resolution by:

• Discussing the matter directly with the individual concerned; or
• Raising the matter with their immediate Supervisor or FunctionalHead.

If the grievance involvesthe Supervisor or cannot reasonably be resolved informally, the employee may proceed to formal submission.

5.2

Formal Grievance Submission

• A formal grievance must be submitted in writingto:
  • The immediate Supervisor; or
  • The Human ResourcesDepartment; or
  • The next-level Manager, CountryHead, if the grievanceinvolves the Supervisor.
• The written grievance should include:
  • A clear description of the issue;
  • Relevant dates, facts and circumstances;
  • Names of individuals involved;
  • Supporting documents (if any);
  • The desired resolution (where applicable).

6.1

Upon receipt of a formal grievance, the Company will:

• Acknowledge receipt within five (5) workingdays.iate Supervisor; or
• Conduct a preliminary review.
• Appoint an impartialinvestigator where appropriate (which may includeHR, management or external advisors where necessary).

6.2

The investigation process may include:

• Interviews with the complainant.
• Interviews with the respondent.
• Interviews with relevant witnesses.
•  Review of relevant documentation and electronic communications.

6.3

All employees are required to cooperate fully and maintain strict confidentiality during the investigation process.

6.4

Investigations will ordinarily be completed within thirty (30) workingdays, subject to complexity and cross-jurisdictional considerations.

7.1

Following completion of the investigation:

• Findings will be documented.
• Appropriate corrective or remedial actions will be determined.
• Relevant parties will be informed of theoutcome, subject to confidentialityand data protection obligations.

7.2

Remedial actions may include:

• Mediation or facilitated discussion.
• Training orcounselling.
• Clarification of policies or reporting lines.
• Disciplinary action where misconduct is substantiated.

8.1

The Company strictlyprohibits retaliation againstany employee who raises a grievance in goodfaith or participates in an investigation.

8.2

Any act of retaliation will constitute a breach of Company policy andmay result in disciplinary action.

9.1

All grievance matters will be handledwith discretion and confidentiality,consistent with applicable dataprotection laws.

9.2

Information will be disclosed strictly on a need-to-know basis to facilitate a fair and properinvestigation.

10.1

Employees who knowingly submit false, malicious or bad-faith allegations may be subject to disciplinary action.

11.1

The Human Resources Department will maintain proper records ofgrievances and investigation outcomes in accordance with the Group’s DataProtection and Record Retention policies.

12.1

Failure to comply with this Policy may result in disciplinaryaction, up to and including termination of employment, in accordance with theEmployee Handbook and applicable laws.

12.2

This Policy shallbe interpreted in accordance with applicable locallaws and regulations in the jurisdiction where the report arises.

12.3

This Policy is subject to regular reviewby the Company and may be revisedperiodically to ensure therobustness of this Policy and to reflect any changes in the Company’soperations or processes or the applicable laws and standards.