Policies

Whistleblowing Policy

Purpose
All ARYZTA entities operating in Ireland (“ARYZTA Ireland”) are committed to conducting business legally and with honesty and integrity. ARYZTA Ireland recognises the valuable service that whistleblowers provide to the business and to the public. This Whistleblowing Policy is designed to encourage and enable all workers to raise concerns about any wrongdoing within the organisation without fear of retaliation. This policy follows the Protected Disclosures (Amendment) Act 2022 and is intended to provide additional localised guidance for the reporting of improper conduct or violations of law in conjunction with the ARYZTA Group Whistleblowing policy.

Scope
This policy applies to all workers associated with ARYZTA Ireland. A “worker” can include any of the following:
• Employees and former employees
• Persons who provide or provided services to ARYZTA Ireland under contract
• Current and former agency workers
• Board and former board members (including non-executive members)
• Shareholders and former shareholders
• Trainees and former trainees
• Volunteers and former volunteers
• Job applicants
• Individuals involved in pre-contract negotiations

Definitions
a) Whistleblower: Any individual who makes a protected disclosure under this policy.
b) Protected Disclosure: A disclosure of relevant information made by a whistleblower in
accordance with the procedures set out in this policy.

What Can Be Reported
ARYZTA Ireland has a zero-tolerance policy regarding unlawful and unethical behaviour in relation to the conduct of our business. All matters raised will be taken seriously and properly investigated. Workers are strongly encouraged to report any concerns or suspicions of the following as early as possible:
• Financial malpractice, misrepresentations, impropriety, or fraud, including accounting and auditing or disclosure concerns
• Failure to comply with a legal obligation (other than a worker’s contract of employment)
• Endangerment of health and food safety
• Risk or damage to the environment
• Criminal activity
• Miscarriage of justice
• Bribery, facilitation of tax evasion or money laundering
• Privacy, confidentiality, and data protection breaches
• Anti-competitive conduct
• Breaches of sanctions
• Violations of human rights, such as modern slavery, child labour and human trafficking
• Wilful breach of any legal obligation such as failure to comply with applicable laws such as
laws relating to environmental protection, food safety, health and safety, consumer
protection, equality, competition, business secrets, insider trading regulations, stock
exchange rules or anti-money laundering procedures etc.
• Attempts to cover up any of these behaviours.

Generally, “unethical behaviour” arises if the actions of a worker would damage ARYZTA’sreputation
if made public. Personal grievances are not covered by this policy unless the behaviour is such that it
impacts the health and safety of others within the workplace. Matters that are purely personal
grievances about another worker should be raised directly with your HR representative.

Confidentiality
All reports made under this policy will be treated with the utmost confidentiality to the extent permitted by law. Confidentiality will be maintained throughout the investigation process, to the extent possible and consistent with a thorough investigation. If you have explicitly consented to disclosure of your identity, this means that your identity will be shared only with those who have a need to know to effectively

conduct any investigation and follow up action (including, if necessary, disciplinary action) on your concern, or where there is a legal requirement to share your identity.
Furthermore, there is an option to make a report anonymously if the worker wishes to do so, the process for which is outlined below.

Reporting Procedures
Workers who have any concerns or suspicions of wrongdoing are strongly encouraged to report these as soon as possible via the internal channel they feel most comfortable with. When reporting concerns, we encourage you to provide as much detail as possible concerning the suspected wrongdoing. This will allow us to conduct any investigation promptly and effectively. You can report your concerns via any of the following options:

Option 1: Your Local HR Department, Managing Director, or Finance Director
You can report your concerns to any of these individuals in person, by phone, email or in
writing. You can request a meeting in person or via video or telephone call to raise your
concern.

Option 2: Speak Up Email Address
You can submit your report directly to the following corporate e-mail address:
[email protected].

Option 3: Group General Counsel
You can report your concerns directly to the Group General Counsel in writing, or by email,
call or in person. You can request a meeting in person or via video or telephone call to raise
your concern.

Option 4: ARYZTA Open Talk Hotline
This hotline is managed by NAVEX, an independent service which is not part of the ARYZTA
Group. The Open Talk ARYZTA Hotline can be contacted at aryzta.ethicspoint.com or via local, toll-free phone numbers that connect reporters to a multilingual reporting service.
Whistleblower will be given the option to instruct the Open Talk Hotline specialist to:
• report the concern to the Responsible Person in the local business; or
• report the concern to the Responsible Person at Group ARYZTA AG level.

ARYZTA Open Talk Contact Info:
Toll-Free number for Ireland – 1800 903 317
Online reporting: www.aryzta.ethicspoint.com

The Hotline is available 24/7 every day of the year, by trained specialists who will answer your
call, document your concerns, and forward a written report to the appropriate responsible
person within the local Company or Group as appropriate, for further investigation.

When you contact the hotline, you may choose to remain anonymous. All reports will be
treated equally whether they are submitted anonymously or not. All concerns about legal or
ethical issues will concerning the ARYZTA Group be treated seriously and discreetly. They will
be investigated and, where needed, corrective action will be taken.

Reporting Externally
Workers also have the right to report a protected disclosure to a regulator, known as a “prescribed person” or to their local Office of the Protected Disclosures Commissioner who will refer the report usually to a suitable regulator, for acknowledgement, follow-up, and feedback. This may occur if the worker does not want to report to their employer or reporting to their employer has not worked. A list of prescribed persons can be found at: www.gov.ie/prescribed-persons.

If all other options fail, workers can make a public disclosure. Such disclosures however are subject to more stringent conditions to qualify for protection.

Feedback
When a worker raises a concern, receipt of the concern will be acknowledged within at least 7 days. Feedback will be given not more than 3 months from the date of acknowledgement of receipt of the concern and at further 3-month intervals on request. No information will be provided that could prejudice the outcome of an investigation or undermine the rights of due process and fair procedure against whom the allegations have been made.

Protection from Retaliation
ARYZTA Ireland is committed to protecting whistleblowers from any form of retaliation because of making a protected disclosure. We aim to encourage openness and will support individuals who raise their reasonable concerns about legal or ethical issues even if they turn out to be mistaken. Retaliation against any whistleblower is strictly prohibited and will be subject to disciplinary action, up to and including termination of employment. If you witness any retaliation or discrimination taking place against a whistleblower, please report it immediately.

Investigation Process
a) All reports will be promptly and thoroughly investigated by the designated Whistleblowing Officer or an appointed investigator.
b) Whistleblowers will be kept informed of the progress and outcome of the investigation to the extent possible without compromising the investigation.

Disciplinary Action
If an investigation substantiates the concerns raised, appropriate disciplinary action will be taken, which may include legal action and termination of employment.

Review and Amendment
This policy will be reviewed regularly to ensure its effectiveness and compliance with applicable laws.
ARYZTA Ireland reserves the right to amend or update this policy as necessary.
ARYZTA Ireland is committed to fostering a culture of openness, accountability, and ethical behaviour.
Employees are encouraged to raise concerns without fear of reprisal.

Date completed: 12.12.2023.

Related Policies:
• ARYZTA Group Whistleblowing policy
• ARYZTA Code of Conduct
• Disciplinary and grievance policy (ARYZTA Ireland)