• a current or former Snap employee, including employees who are permanent, part-time, fixed-term or temporary, interns and students;
• a current or former officer or associate of Snap, including directors or company secretaries;
• a franchise partner of Snap, or any employee of a franchise partner;
• a supplier or contractor who is providing, or has provided, goods or services to Snap, including their employees; or
• a relative, dependent or spouse of an individual identified in (a) to (d) above.

This Policy aims to:

• encourage disclosure of Potential Misconduct;
• help deter Potential Misconduct, in line with Snap's risk management and governance framework;
• provide protection for individuals who disclose Potential Misconduct in good faith, so they can do so safely and securely with confidence that they will receive appropriate protection and support;
• ensure that all disclosures are assessed and investigated thoroughly, fairly and in a timely manner;
• provide transparency around Snap's framework for receiving, managing and investigating disclosures;
• support Snap's long-term sustainability and reputation; and
• ensure Snap meets its legal and regulatory obligations.

Snap encourages any individual identified in section 2 to report Potential Misconduct. Individuals are expected to have Reasonable Grounds to suspect that the information they are disclosing is true and accurate based on first-hand knowledge. They will not be penalised if the information ultimately proves to be incorrect.

Examples of Potential Misconduct include, but are not limited to:

• failure to comply with, or breach of, legal or regulatory requirements;
• breach of Snap's Code of Conduct or other Snap policies, standards or codes;
• engaging in or threatening to engage in detrimental conduct against a person who has made, or is suspected of planning to make, a disclosure;
• illegal conduct, such as theft, dealing in or use of illicit drugs, violence or threatened violence, or criminal damage to property;
• fraud, money laundering or misappropriation of funds;
• offering or accepting a bribe;
• financial irregularities;
• breaches of the Modern Slavery Act 2018 (Cth);
• discrimination, vilification, harassment, bullying or victimisation;
• actions causing financial, operational or reputational harm to Snap;
• unsafe or reckless work practices; and
• any deliberate concealment of the above.

To avoid doubt, Potential Misconduct does not include personal work-related grievances — that is, matters relating to an individual's current or former employment or engagement that are personally related to that person and do not have broader implications for Snap.

Examples of personal work-related grievances include:

• an interpersonal conflict between an individual and another employee;
• a decision that does not involve a breach of workplace laws;
• a decision about an individual's engagement, transfer or promotion;
• a decision about an individual's terms and conditions of engagement; or
• a decision to suspend, terminate or otherwise discipline an individual.

A personal work-related grievance may, however, still qualify for protection under this Policy if:

• it includes information about Potential Misconduct, or is accompanied by a personal work-related grievance;
• there is a breach of employment or other laws punishable by imprisonment for 12 months or more;
• an individual engages in conduct that represents a danger to the public; or
• an individual suffers from, or is threatened with, detriment for making a disclosure.

Individuals are encouraged in the first instance to raise matters relating to their personal circumstances through normal Snap channels, unless they believe they may suffer personal detriment by doing so or they wish to use the protections available under this Policy.

Knowingly making false, malicious or misleading reports is a serious breach of this Policy and may result in disciplinary or other appropriate action, up to and including termination of employment or contract. Deliberately false or reckless disclosures may also attract legal consequences.

Disclosures of Potential Misconduct may be made to any of the following:

• a Snap manager;
• Snap HR;
• a legal practitioner for the purpose of obtaining legal advice or representation; or
• any independently managed whistleblower hotline service maintained by Snap from time to time.

Contact details for each reporting option are included in Appendix B of this Policy.

A disclosure made to an independently managed hotline automatically qualifies for whistleblower protection under the Whistleblower Legislation.

Potential Misconduct reports should include as much relevant information as possible, including names, dates, locations and any supporting evidence.
Snap encourages individuals to make disclosures through the internal and external reporting channels identified in this Policy wherever possible. Early reporting helps Snap identify and address

Potential Misconduct promptly and supports a transparent and trustworthy process for managing concerns.

Disclosures may also be made directly to relevant regulatory bodies, including the Australian
Securities and Investments Commission (ASIC), the Australian Prudential Regulation Authority (APRA) or the Australian Taxation Office (ATO).

Individuals may choose to make a disclosure on a confidential, partially anonymous or fully anonymous basis.

Anonymous disclosures may limit Snap's ability to investigate or provide updates; however, Snap will still assess any information provided to the extent reasonably possible.

Confidential disclosure
The individual's identity is known to Snap HR and any personnel who need to be involved in assessing or investigating the matter. This is generally the most effective option, as it enables a thorough investigation and allows Snap to provide appropriate support and protection.

Partially anonymous disclosure
Snap HR knows the individual's identity, while a pseudonym is used so that other stakeholders are not aware of who made the report. This approach may limit the extent to which an investigation can progress.

Anonymous disclosure
The individual does not reveal their identity to anyone. While this option remains available, it may restrict Snap's ability to investigate the matter, seek clarification or offer the same level of practical support to the individual.

Snap is committed to protecting the identity of individuals who make a disclosure. An individual's identity (and any information that could reasonably lead to their identification) will only be released with their consent, or in limited circumstances where disclosure is permitted or required by law.

All materials, documents, records and related information generated in connection with an investigation into Potential Misconduct will be securely stored and handled on a confidential basis. Access will be restricted to those personnel who need the information to manage or investigate the disclosure. Only a limited number of authorised individuals will be made aware of an individual's identity (subject to their consent) or any information that would reasonably reveal it. Where this occurs, the whistleblower will be informed beforehand wherever possible.

If an individual believes there has been a breach of confidentiality under this Policy, they may lodge a complaint with Snap HR or raise the matter with the relevant regulatory authority.

A whistleblower may be entitled to protection from civil, criminal and administrative liability (including disciplinary action) in relation to making a disclosure. These protections do not, however, provide immunity for any Potential Misconduct an individual may have engaged in, and which is revealed as part of the disclosure.

Snap will take reasonable steps to protect and support whistleblowers during and after the disclosure process. This may include HR assistance, adjustments to duties or work arrangements, measures to protect wellbeing and actions to prevent or address detrimental conduct.

It is unlawful for any person to cause detriment (or threaten to do so) because they believe or suspect that a disclosure has been, may be, or will be made. Detrimental conduct includes, without limitation, dismissal, disciplinary action, changes to duties to an individual's disadvantage, discrimination, harassment, intimidation, psychological harm, and damage to property, reputation, business or financial interests.

Reasonable management action — such as performance management conducted in accordance with Snap's policies — is not considered detrimental conduct. Measures taken to protect an individual from risk of detriment (for example, temporary changes to reporting lines, duties or work location) are also not considered detriment.

If an individual believes that they have been, or may be, subjected to detrimental conduct in connection with a disclosure, they should report the matter to the Whistleblower Protection Officer (WPO) immediately. An individual may also seek independent legal advice or contact the relevant regulatory body.

Anyone engaging in unlawful detrimental conduct may be subject to disciplinary action, up to and including termination of employment or contract. The protections in this Policy extend to individuals who assist in an investigation, including individuals perceived to be whistleblowers.

All reports of misconduct under this Policy will be handled promptly, fairly and impartially. The response will depend on the nature of the disclosure and the information provided, and may involve informal resolution or a formal investigation.

A disclosure does not guarantee a formal investigation. All reports will be assessed by Snap HR, who will determine whether an investigation is warranted. Snap acknowledges that it may not be possible to investigate a disclosure if it cannot contact the discloser (for example, where a report is made anonymously and no contact details were provided). Snap will still assess the information to the extent reasonably practicable.

If an investigation is required, the Management Team will investigate with the objective of confirming or refuting the alleged Potential Misconduct. External specialists may be engaged where appropriate.

If the disclosure involves the CEO or a member of the Board, another appropriate senior leader or external specialist will oversee the investigation to ensure independence. The Snap Board will oversee the investigation to ensure confidentiality is maintained.

Snap will conduct investigations in a timely, independent and fair manner. Snap employees and contractors must cooperate fully. Where appropriate and permitted by law, individuals who are the subject of an investigation will be provided with relevant details and an opportunity to respond.

The Management Team will collect and secure relevant documents, information and evidence, and will prepare objective findings and recommendations for reporting to the Snap Board. If the allegation relates to a member of the Management Team, the findings will be escalated to senior leaders who are not implicated to ensure independence in the review process.

Snap is committed to implementing investigation findings and recommendations to address and rectify wrongdoing wherever practicable. If wrongdoing is established, the report will outline corrective actions, disciplinary measures or referral to external authorities as required.

• confirmation that the disclosure has been received;
• notification that an investigation has commenced;
• progress reports during the investigation; and
• advice when the investigation has concluded.

• personal information and any references that could reasonably identify the whistleblower are redacted and securely stored;
• the whistleblower is described in gender neutral terms;
• where practicable, the whistleblower is consulted to identify any elements of their disclosure that may inadvertently reveal their identity; and
• disclosures are managed and investigated by a designated Whistleblower Investigation Officer (WIO).

This Policy may be updated from time to time. Any revised version will be published on the Snap intranet and will take effect from the date it is posted.

DEFINITIONS