Whistleblower Policy

VND Global Holdings Limited ("VND Global" or the "Company") is committed to maintaining the highest standards of integrity, transparency, accountability, and ethical conduct in all aspects of its operations. This Whistleblower Policy establishes a framework through which individuals may raise genuine concerns regarding suspected misconduct, unlawful activity, or serious ethical breaches relating to the Company. The policy is designed to ensure that such concerns may be raised safely, confidentially, and without fear of retaliation.

This policy applies to individuals who obtain information about potential misconduct in connection with the Company, including but not limited to: — current and former employees — officers and directors — contractors, consultants, and suppliers — associates and business partners — any other person interacting with the Company in a professional capacity Such individuals are collectively referred to as "Eligible Whistleblowers" for the purposes of this policy.

This policy is intended to facilitate the reporting of serious concerns relating to the conduct of the Company or its personnel. Matters that may be reported under this policy include, but are not limited to: — fraud, financial misconduct, or misappropriation of assets — bribery, corruption, or improper inducements — serious breaches of legal or regulatory obligations — misconduct relating to accounting, internal controls, or financial reporting — significant risks to health, safety, or the environment — conflicts of interest that are not properly disclosed or managed — deliberate concealment of any of the matters listed above — conduct that could materially harm the integrity, reputation, or lawful operation of the Company This policy is not intended to address personal employment grievances that relate solely to an individual's employment conditions. Such matters should be raised through the Company's standard internal procedures where appropriate.

Eligible Whistleblowers may raise concerns confidentially through the following channels: Confidential Email whistleblower@vndglobal.com Written Submission Board of Directors VND Global Holdings Limited Marked: Strictly Private and Confidential Reports may be submitted anonymously. While anonymous disclosures are accepted and will be considered in good faith, providing contact information may assist the Company in conducting an effective investigation.

All disclosures made under this policy will be handled with strict confidentiality to the fullest extent permitted by applicable law. The identity of a whistleblower will not be disclosed without their consent unless such disclosure is required by law or is reasonably necessary in order to conduct an investigation. In circumstances where disclosure of information is necessary, the Company will take reasonable steps to reduce the risk that the whistleblower will be identified. Information obtained through whistleblower reports will be accessed only by individuals who are authorised to investigate or manage the matter.

The Company strictly prohibits retaliation against any individual who makes a disclosure in good faith under this policy. Retaliation includes any form of detrimental conduct such as dismissal, demotion, harassment, discrimination, intimidation, or any other adverse treatment arising from the disclosure. Any individual found to have engaged in retaliation against a whistleblower may be subject to disciplinary action, including termination of employment or contractual arrangements.

This policy is intended to protect individuals who raise concerns honestly and in good faith. Disclosures that are knowingly false, malicious, or made with reckless disregard for the truth may result in disciplinary action or other appropriate consequences.

All disclosures will be assessed promptly and handled in accordance with appropriate governance procedures. Where a matter warrants further review, the Company may conduct a formal investigation. Investigations may be undertaken by authorised internal personnel or, where appropriate, by independent external legal, accounting, or governance advisors in order to ensure impartiality. To the extent permitted by confidentiality obligations and legal requirements, the whistleblower may be informed of the general progress or outcome of the investigation.

The Company will maintain secure records of whistleblower disclosures and any associated investigations. Such records will be retained in accordance with applicable data protection, confidentiality, and record-keeping obligations. Access to these records will be restricted to authorised individuals involved in the management of the disclosure or investigation.

Nothing in this policy prevents an individual from reporting concerns to relevant regulatory authorities, law enforcement agencies, or other external bodies where permitted or required by law.

Oversight of this Whistleblower Policy rests with the Board of Directors of VND Global Holdings Limited. Where appropriate, significant disclosures may be reported to the Board or to designated governance advisors to ensure proper oversight, independence, and integrity of the investigative process.

This policy will be reviewed periodically and updated where necessary to reflect changes in applicable laws, regulatory expectations, and best governance practices.

For questions regarding this policy or the whistleblower process, individuals may contact: VND Global Holdings Limited whistleblower@vndglobal.com