Whistleblower Policy

INTRODUCTION

17 Sport is committed to high standards of openness, honesty, and accountability. An important aspect of this is a mechanism to enable all stakeholders of 17 Sport to voice concerns in a responsible and effective manner, without fear of reprisal. Effective whistleblowing policies also relate to the UN Sustainable Development Goal (SDG) 16: Peace, justice, and strong institutions.

Please note, 17 Sport Stakeholders include, but are not limited to, our team members, and our external collaborators. Please see our Stakeholder Engagement Policy for a more detailed list of our key stakeholders, all of whom are covered by this policy.

As a French headquartered business, our Whistleblower Policy is in line with the EU Whistleblower Directive, and relevant French laws, including:

• The “Loi Sapin 2” which created common rules for whistleblowing across the sectors. Loi Sapin 2 gives legal protection to employees against being dismissed or penalized by their employers as a result of publicly disclosing certain serious concerns.

• The 2022 amendments, introduced through Law No. 2022-401 on March 21, 2022, which were designed to transpose the EU Whistleblowing Directive (2019/1937) into French law, aiming to improve the protection of whistleblowers.

• Décret n°2022-1284 of October 3rd, 2022 on procedures for collecting and processing whistleblower disclosures and establishing the list of external authorities set up by the aforementioned law.

Please see Whistleblowers in company | Service-Public.fr for detailed information on Whistleblower rights and protections in France, to which 17 Sport adhere. If you would like to make a complaint, we advise that you first read this policy in full.

SCOPE OF POLICY

This policy is designed to enable 17 Sport’s stakeholders, and more specifically the persons identified below, to raise concerns and to disclose information that the individual believes shows malpractice or impropriety by the company—or in other words act as a whistleblower. Persons who can act as whistleblowers are anyone who has obtained, in the course of their professional activities, information regarding facts that have occurred or are very likely to occur within the company.

17 Sport may make a report under this internal procedure, provided they belong to one of the following categories:

• Employee of the 17 Sport former employee, or job applicant;

• Shareholder, partner, and holder of voting rights within the general assembly;

• Members of the administrative, management, or supervisory body;

• External or occasional collaborators;

• Business partner, subcontractor, or a member of the staff or governing body of a business partner or subcontractor.

The whistleblower status requires several criteria:

• The individual must be a natural person, understood as a living human being, as opposed to a legal entity or "juristic person";

• The individual must act in good faith, meaning without malicious intent;

• The individual must report the facts without any direct financial compensation.

This policy covers concerns that are in the public interest, and discusses what measures will be taken to investigate, and what whistleblowers may expect in terms of process and protection. Consent of employees and / or stakeholders is not required for introducing a whistleblowing program, but employees must be informed, and any related policies must be publicly available via the 17 Sport website for external stakeholders to access.

SUBJECTS THAT ARE COVERED BY WHISTLEBLOWER PROTECTION

Whistleblowing disclosures must be limited to the reporting of:

• A crime or illegal act.

  • Example: An employee discovers that an employee is falsifying data regarding the inclusivity of certain sports programs, or is engaging in corrupt practices to secure sponsorships or partnerships.

• A serious and clear breach of an international engagement ratified or approved by France, or of a unilateral act; of an international organization based on such an engagement.

  • Example : The company violates international agreements related to diversity and inclusion in sports by failing to comply with anti-discrimination policies established by the International Olympic Committee (IOC) or other global sports organizations.

• A serious and clear breach of the law or regulation.

• A threat or serious prejudice for general public interest.

  • Example: The company, in its promotion of sports events, knowingly excludes marginalized communities thereby hindering the public's access to equal participation in sports activities.

• A threat or serious prejudice for health or environment.

WHY A REPORTED ISSUE MAY NOT BE ACCEPTED AS A GRIEVANCE UNDER THIS POLICY

It should be emphasized that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question general financial or business decisions taken by the Company, nor should it be used to reconsider any matters that have already been addressed under harassment, complaint, disciplinary, or other procedures.

An issue may also not be accepted as a grievance—and investigated separately—if it does not fall into one of the categories listed above. Additionally, facts, information or documents covered by national defense, medical or lawyer/client confidentiality, judicial inquiry or investigation, and judicial deliberations are currently excluded from whistleblowing rules.

SAFEGUARDS

There are several safeguards in place to ensure that 17 Sport follows correct procedures regarding receiving a complaint from a whistleblower.

PROTECTION

This policy is designed to offer protection to all stakeholders of 17 Sport from any form of retaliation for using any grievance or complaints mechanism outlined within this policy. The disclosure should be made in good faith, and the whistleblower must have reasonable grounds to believe that the information they are reporting is accurate.

Under Article L 1121-1 of the French Labor Code, no person qualified as a whistleblower may be excluded from a recruitment process, access to an internship, or a training period within the company. No employee may be sanctioned, dismissed, or subject to any direct or indirect discriminatory measure, including but not limited to those related to compensation, profit-sharing or stock distribution, training, redeployment, assignment, qualification, classification, professional promotion, working hours, performance evaluation, transfer, or contract renewal. Furthermore, no employee may be subjected to reprisals or threats, such as being improperly directed towards psychiatric or medical treatment or having their reputation harmed, for reporting or disclosing a disclosure in compliance with the conditions set forth in this policy or the reporting conditions defined by law.

Under the same conditions, individuals who are not covered by Article L 1121-2 of the French Labor Code (such as external collaborators and the company's co-contractors) may not be subjected to reprisals, threats, or attempts to apply such measures, in any form they may take. Facilitators (individuals who assist a whistleblower in making a report) and individuals connected to the whistleblower are also protected against reprisals, threats, or attempts to resort to such measures.

17 Sport and its representatives may not make any agreements with individuals that prevent them from making a protected disclosure.

More details on protection from retaliation can be found in our No Retaliation Policy.

GUARANTEE OF CONFIDENTIALITY OF IDENTITY

17 Sport will treat all such disclosures in a confidential and sensitive manner. Only authorized individuals responsible for receiving and processing reports may have access to the information collected. As per Whistleblowers in company | Service-Public.fr, the confidentiality of the identity of the reporting parties, the persons referred to and any third party mentioned in the report shall be guaranteed. The particulars likely to identify the whistleblower may not be disclosed without their agreement. However, in certain cases they may be forwarded to the judicial authority. Where the persons responsible for collecting or processing disclosures have to report the facts collected to the judicial authority, the information likely to identify the whistleblower may also be communicated to them. In this case, the whistleblower shall be informed.

ANONYMOUS ALLEGATIONS

This policy encourages individuals to put their names on any disclosures they make. Concerns expressed anonymously will be considered at the discretion of 17 Sport. In exercising this discretion, the factors to be taken into account will include:

• The seriousness of the issues raised;

• The factual elements are sufficiently detailed;

• The likelihood of confirming the allegation from attributable sources.

UNTRUE ALLEGATIONS

If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual.

PROCEDURES FOR MAKING A DISCLOSURE

WHAT TO INCLUDE IN YOUR REPORT

It is preferable to provide a written notification when making a disclosure. The author of the report is encouraged, to the extent possible, to include:

• The date of the reported events, the location, the person(s) involved, and a detailed description of the facts;

• Any evidence, regardless of its form or medium, that could support the report;

• Contact details to facilitate communication with the recipient of the disclosure (email address, phone number, postal address, etc.)

REPORTING PATHWAYS

If an individual wishes to issue a report, they have the option to choose to report into 17 Sport, henceforth referred to as “internal reporting”, or to a third party, henceforth referred to as “external reporting”.

INTERNAL REPORTING

For internal stakeholders, such as employees, the whistleblower would in the first instance speak with their Growth Manager. For external stakeholders, the whistleblower should first contact 17 Sport Impact and People Manager Emma Kennedy on emma@17-sport.com, or to 17 Sport Head of Finance and Administration Laurent Igolen on laurent@17-sport.com if the report concerns the Impact and People Manager. In either case, the recipient of the disclosure must deal with the admissibility of the report within 7 business days. will

Whether an internal or external whistleblower, in the case you feel the answer is not timely nor appropriate, you may escalate the discourse to the most relevant of the following:

• Internal HR: emma@17-sport.com;

• External HR: flore.jeanteur@smashgroup.fr;

• 17 Sport Co-Founders: neill@17-sport.com and fabien@17-sport.com.

EXTERNAL REPORTING

Should none of the above routes be suitable or acceptable to the whistleblower, then they may report externally. Please note, external reporting may be carried out before, during, or after internal reporting. The report may be filed with the following authorities or institutions:

• Defender of Rights, who process the report if it falls within its areas of competence (including discrimination), or who will refer it to the authority or authorities best placed to handle the issue;

• Judicial authority, which will process the report if the facts reported fall within its jurisdiction, in particular where they may constitute a criminal offence.

• Competent EU institution, body, office or agency in the event of a breach of EU law ;

• One of the authorities listed in the annex to Decree 2022-1284 of October 3, 2022 in particular :

  • HAS: High Health Authority, for matters relating to health and medical practices, particularly public health and medical device safety;

  • CNIL (French Data Protection Authority) in matters of privacy and personal data protection.

  • DGT: Directorate-General for Labor, in matters related to individual and collective labor relations and working conditions

INVESTIGATING PROCEDURE

The investigating officer must follow these steps:

1. The author of the report is informed in writing of the receipt of their report within 7 business days from the date of receipt. This deadline is informed by Law “Sapin” 2.

2. Full details and clarifications of the complaint should be obtained.

3. The investigating officer should inform the member of staff, or relevant stakeholder, against whom the complaint is made as soon as is practically possible. They will be informed of their right to be accompanied by a work colleague at any future interview or hearing held under the provision of these procedures. At the discretion of the investigating officer and dependent on the circumstances of the complaint an alternative representative may be allowed e.g. the individual’s legal representative.

4. The investigating officer should consider the involvement of the Company auditors and the Police at this stage and should consult with the 17 Sport Co-Founders if appropriate.

5. The allegations should be fully investigated by the investigating officer with the assistance where appropriate, of other individuals / bodies.

6. A judgment concerning the complaint and validity of the complaint will be made by the investigating officer. This judgment will be detailed in a written report containing the findings of the investigations and reasons for the judgment. The report will be passed to the 17 Sport Co-Founders as appropriate.

7. The 17 Sport Co-Founders will decide what action to take.

8. If appropriate, a copy of the outcomes will be used to enable a review of Company procedures.

WHISTLEBLOWER COMMUNICATION

Once the internal report is received, 17 Sport will communicate to the whistleblower, within a reasonable period not exceeding 3 months from the acknowledgment of receipt, information regarding:

1. The measures considered or taken to assess the accuracy of the allegations;

2. The measures taken to address the subject of the report, if applicable;

3. The reasons for the decisions made.

If the whistleblower is not satisfied that their concern is being properly dealt with by the investigating officer, they have the right to raise it in confidence with the 17 Sport Co-Founders, or one of the designated persons described above.

INFORMATION FOR PERSON OR PERSONS NAMED IN DISCLOSURE

Any person, or persons, subject to a disclosure will be informed by the investigating officer. They will receive details of what they are accused of, in order to exercise their right to defense. They will not receive any information regarding the identity of the whistleblower or the third parties mentioned in the report.

This information must be provided within a reasonable period, not exceeding one month. However, it may be delayed if it is likely to severely compromise the investigation, particularly if there is a risk of evidence being destroyed.

PROCESSING OF PERSONAL DATA

Caution will be applied when processing any personal data in the context of HR management (including handling whistleblowing). 17 Sport shall comply with GDPR, relevant applicable laws, and internal policies regarding data protection.

The person responsible for processing the disclosure takes all necessary measures to preserve the integrity and security of the data throughout the duration of its processing and retention, in accordance with our Data Protection Policy.

Measures specific to this policy include:

• Data related to an disclosure deemed inadmissible, as not falling within the scope of this policy, is promptly destroyed or archived after anonymization.

• Data related to a disclosure not followed by disciplinary or legal action is destroyed or archived, after anonymization, within 2 months from the closure of the verification process.

• When a disciplinary procedure or legal action is initiated against the person targeted by the disclosure or the author of an abusive disclosure, the data related to the disclosure is retained until the conclusion of the procedure or legal action, or until the expiration of the time limit for filing appeals against the decision.

• Unless no action is taken on the disclosure, the data controller may retain the collected data in the form of intermediate archives for a maximum period of 3 years to ensure the protection of the whistleblower or to allow the identification of ongoing violations.

FURTHER INFORMATION

This policy can be found in the Team Handbook - 17 Sport - April 2025, as well as publicly via the 17 Sport website. If you have a question on this policy, please contact 17 Sport’s Impact and People Manager Emma Kennedy on emma@17-sport.com.

For more information on regulations applicable in France, please see the following resources:

• Guide for whistleblowers 2023

• Whistleblowers in company | Service-Public.fr