1. Purpose and Commitment

Starbien Sp. z.o.o. (“Starbien”, “the Company”, “we”, “our”) is committed to maintaining the highest standards of ethics, transparency, and compliance in all areas of its operations. This Whistleblower Policy establishes secure and confidential procedures for **reporting suspected misconduct, breaches of law, unethical behavior, or violations of internal regulations**, including AML/CFT, data protection, and financial integrity rules.

The purpose of this Policy is to:

• Encourage employees and external parties to report wrongdoing without fear of **retaliation**.
• Ensure that all reports are handled fairly, promptly, and confidentially.
• Promote a culture of integrity and accountability across the organization.

2. Scope of the Policy

This Policy applies to:

• All employees, including full-time, part-time, and temporary staff.
• Contractors, consultants, and third-party partners working with Starbien.
• Customers or external stakeholders who wish to report suspected misconduct affecting the Company’s operations.

Covered matters include, but are not limited to:

• Violations of applicable laws and regulations.
• Fraud, corruption, money laundering, or terrorist financing.
• Bribery or abuse of authority.
• Breaches of personal data protection or confidentiality.
• Manipulation or falsification of records or reports.
• Any behavior inconsistent with Starbien’s ethical and compliance standards.

3. Reporting Channels

Starbien provides multiple secure and confidential channels for submitting whistleblower reports:

Email: support@starbien.com

In Writing:
Starbien Sp. z.o.o.
Attn: Compliance Department
Plac Bankowy 2/1309, 00-095 Warsaw, Poland

Anonymous Submissions:
Reports may be submitted **anonymously**. However, providing contact information can assist the Company in conducting a thorough and effective investigation. Anonymous reports will still be reviewed and investigated with equal diligence.

4. Reporting Procedure

When submitting a report, the whistleblower should provide:

• A clear description of the alleged misconduct.
• Relevant facts, dates, and any available evidence.
• Names or positions of the persons involved (if known).
• Any potential witnesses or other supporting details.

All reports are acknowledged within **7 calendar days** of receipt, and an internal investigation will begin promptly. The Company aims to complete the review and provide a formal response or status update within **3 months**, in accordance with the EU Whistleblower Directive.

If the issue cannot be resolved within this timeframe, the whistleblower will be informed of the reason for the delay and the expected completion date.

5. Confidentiality and Data Protection

All whistleblower communications are handled with **strict confidentiality**. The identity of the whistleblower, the subject of the report, and any third parties mentioned will be disclosed only to individuals directly involved in the investigation process.

Starbien ensures that all data collected during the whistleblowing process is processed in compliance with the **General Data Protection Regulation (GDPR)** and the Polish Data Protection Act. Reports are securely stored for the period necessary to complete the investigation and fulfill any legal requirements.

6. Non-Retaliation Guarantee

Starbien strictly prohibits any form of **retaliation, harassment, or adverse treatment** against individuals who, in good faith, report concerns or cooperate in investigations.

This protection applies even if an investigation finds that no violation occurred, provided the report was made honestly and without malicious intent. Any employee found to engage in retaliatory behavior will be subject to disciplinary action, up to and including termination.

If a whistleblower believes they have been subjected to retaliation, they should report this immediately to the Compliance Department or directly to management.

7. Investigation and Follow-Up

Upon receipt of a report, the Compliance Department or designated investigator will:

• Acknowledge receipt within 7 days.
• Conduct a preliminary assessment to determine if further investigation is warranted.
• If appropriate, launch a full investigation involving relevant departments and external advisors.
• Maintain objectivity, fairness, and confidentiality throughout the process.
• Document findings and recommend corrective or disciplinary actions.

The whistleblower will be informed of the outcome or progress, subject to confidentiality and legal constraints.

8. False or Malicious Reports

While Starbien encourages all legitimate concerns to be reported, knowingly making false, frivolous, or malicious allegations is a **serious violation** of this Policy and may result in disciplinary action.

However, a report made in good faith that is ultimately found to be unsubstantiated will not result in any adverse consequences for the whistleblower.

9. External Reporting

In accordance with the EU Whistleblower Directive, individuals may also report concerns directly to external authorities if:

• Internal channels are unavailable or inappropriate.
• There is a risk of retaliation.
• The matter involves senior management or the Board.
• An internal report has not been addressed within a reasonable timeframe.

External reporting may be made to the Polish competent authorities or EU institutions, depending on the nature of the concern.

10. Policy Review

This Whistleblower Policy is reviewed **annually** and updated as needed to ensure compliance with legal and regulatory developments, including the EU Whistleblower Protection Directive (2019/1937).

11. Contact Information

For questions or to submit a whistleblower report, contact:

Starbien Sp. z.o.o.
Email: support@starbien.com
Address: Plac Bankowy 2/1309, 00-095 Warsaw, Poland