Whistleblowing Notice

WHISTLEBLOWING NOTICE

What is whistleblowing?

Whistleblowing refers to the reporting of concerns, suspicions, or observed misconduct within an organization. Whistleblowers play a vital role in upholding transparency, integrity, and regulatory compliance.

At Cube, we provide individuals with a trusted and confidential avenue to raise concerns about potential misconduct, fraud, or violations of legal, regulatory, or policy obligations. By speaking up, whistleblowers help protect the interests of our users, counterparties, and the broader market, and contribute to a culture of accountability and ethical conduct.

When should I blow the whistle?

You should consider raising a concern if you have reasonable grounds to believe that:

• Fraudulent activities are taking place, including embezzlement, corruption, misappropriation of funds, or manipulation of financial records.
• Laws, regulations, or Cube's internal policies are being violated — for example, through insider trading, market manipulation, or breaches of customer confidentiality.
• Anti-money laundering, counter-terrorism financing, or sanctions obligations are not being met.
• The health or safety of any individual is being endangered.
• Other significant risks to stakeholders, users, or the integrity of the exchange are being ignored or concealed.

How do I raise a whistleblowing concern?

You can submit a report by contacting us at legal@cube.exchange. Your report should include as much detail as possible, including:

• A description of the alleged misconduct
• The dates on which the conduct occurred or is occurring
• The individuals involved
• Any supporting evidence or documentation

All reports will be treated with strict confidentiality and investigated promptly and impartially by an appropriate member of the Cube compliance or legal team or, where circumstances require, escalated to the Board.

What protections are in place for whistleblowers?

Cube is committed to protecting the confidentiality of all whistleblowers to the fullest extent permitted by applicable law. We do not tolerate retaliation against any individual who raises a concern in good faith, whether or not the concern is ultimately substantiated.

Whistleblowers who report concerns in good faith can expect that:

• Their identity will be kept confidential wherever possible.
• Their report will be taken seriously and assessed objectively.
• They will not suffer any adverse employment, professional, or contractual consequence as a result of having reported.

Anonymous reports are also accepted, though we note that anonymity may limit our ability to investigate effectively or provide feedback on the outcome.

Anti-bribery and corruption

Cube has zero tolerance for bribery and corruption. Each Cube Group entity is committed to conducting its business with integrity and in accordance with applicable anti-bribery and anti-corruption laws, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and equivalent legislation in all jurisdictions in which we operate.

If you know of or suspect any bribery or corrupt conduct involving any Cube employee, contractor, or associated person, please report it immediately to legal@cube.exchange with all relevant details.