Whistleblowing Guidelines

You can submit a Report using the following channels:

• Online reporting: Go to Feedzai
• Hotline, available here and follow the instructions provided there, or
  Telephone reporting: Go to the Call Us section of Feedzai Hotline and follow the instructions. Please note that telephone reporting calls will be transcripted.

You will receive confirmation that your report was successfully submitted.

Yes, you have the option to remain anonymous both in Reports made through the website or the telephone hotline, if the law of your country allows it. However, please bear in mind that anonymity may prevent a fast and/or exhaustive investigation.

Our Whistleblowing Officers will receive your Reports and proceed with any necessary investigations. In some cases, additional Investigators (such as Feedzai employees with relevant knowledge for the investigation, lawyers or others) may also be involved in the investigation of your Report.

Feedzai Hotline covers any irregularities or complaints regarding the following matters (“Compliance Matters”):

• Fraud, deliberate error, gross negligence or recklessness in the preparation, evaluation, revision or audit of any financial statements or other disclosures of Feedzai;
• Fraud, deliberate error, gross negligence or recklessness in the recording and maintenance of financial records or other disclosures of Feedzai;
• Deficiencies in or non-compliance with Feedzai’s internal accounting controls;
• Misrepresentation or false statements to management, regulators, to outside auditors or others, or by management, or any other employee concerning a matter contained in the financial records or reports or audit reports, or regarding other disclosures of Feedzai;
• Deviation from full and fair reporting of Feedzai’s results or financial condition;
• Breaches of the European Union (“EU”) law in the areas of (i) public procurement, (ii) financial services, products and markets and prevention of money laundering and terrorism financing, (iii) product safety and compliance, (iv) transport safety, (v) environment protection, (vi) radiation protection and nuclear safety, (vii) food and feed safety, animal health and welfare, (viii) public health, (ix) consumer protection, (x) privacy and personal data protection, and security of network and information systems, (xi) competition and state aid rules, (xii) acts with the purpose of obtaining a tax advantage that defeats the object or purpose of the applicable corporate tax law or (xiii) breaches affecting the financial interests of the EU;
• Other infringements of any laws, rules or regulations applicable to Feedzai;
• Activities or transactions that violate or appear to violate Feedzai’s internal policies;
• Miscarriages of justice and deliberate concealing of information about any of the above;
• Retaliation against employees or contractors who, in good faith, report any irregularity or concern regarding any of the items above.

We encourage you to provide as much detail as possible. This will help our Whistleblowing Officers (and any Investigators, if applicable) with the investigation of your Report.

Useful information include:

• Date(s), time, and if relevant, location(s);
• Names of the involved person(s), roles and their team;
• Your relationship with the involved person(s);
• The general nature of your concern or irregularity;
• How you became aware of the matter;
• Possible witnesses; and
• Any other details you can provide to support and complete your Report.

Yes. Feedzai will keep all discussions and actions with respect to a Report confidential to the maximum extent possible. However, Feedzai may find it necessary to share information on a “need to know” basis during the course of any investigation, for the sole purpose of conducting the investigations.

As mentioned in the previous answers, your Report will be received by our Whistleblowing Officers, and additional Investigators may need to be involved.

Your Report may also need to be disclosed to the public authorities in case it gives rise to a criminal investigation or, where the involved person(s) is/are not employed by Feedzai, to their respective employer.

You will have the possibility of checking the status of your Report using the “check status” option available in Feedzai Hotline.

Note that you will be informed when the investigation is closed but only updated about the results of any investigation (including any corrective actions taken) if possible, as it may be inappropriate to give such an update for various reasons, notably, due to confidentiality or other applicable legal obligations.

Yes, the Whistleblowing Officers will keep records of all Reports and complaints submitted through Feedzai Hotline, and of the results of any investigations.

The Whistleblowing Officer assigned to your Report, with the assistance of Investigators (when appointed) will determine when the investigation is complete.

Once the investigation is complete, they will document the conclusions of the issues identified in your Report, and identify the proposed corrective actions to be taken, if any.