Whistleblower Policy

NetComm Wireless Ltd (NetComm and now a wholly owned subsidiary of Casa Systems, Inc.) is committed to creating and maintaining an open working environment in which past and present employees, directors (whether they are full-time, part-time or casual), contractors, suppliers, partners and consultants are able to raise concerns regarding actual or suspected unethical, unlawful or undesirable conduct.

The Board of Directors and Leadership Team recognises that any genuine commitment to detecting and preventing illegal and other undesirable conduct must include a mechanism whereby employees and others can report their concerns freely and without fear of reprisal or intimidation. The Whistleblower Policy and Procedure provides such a mechanism and encourages the reporting of such conduct. Unethical, unlawful, undesirable conduct or an improper state of affairs is referred to in this Policy as Misconduct.

• Promote an open and transparent culture within NetComm
• Encourage employees, directors, contractors, suppliers, partners and consultants to report an issue if on reasonable grounds they believe a person or persons has breached the NetComm Code of Conduct, policies or the law.
• Demonstrate NetComm’s commitment to a fair workplace and outline the process for managing matters of Misconduct.
• Protect individuals who have reasonable grounds , report Misconduct which they reasonably believe to be corrupt, illegal or unethical on a confidential basis and if requested anonymously, without fear of reprisal, dismissal or discriminatory treatment.
• Assist in ensuring that matters of Misconduct and/or unethical behaviour are identified and dealt with appropriately.

This Policy applies to all NetComm operations and its wholly owned operating subsidiaries employees, former employees, directors, (whether they are full-time, part-time or casual), contractors, suppliers, partners and consultants

Misconduct: All NetComm past and present employees, directors, contractors and consultants are encouraged to report any genuine concerns that they believe constitute a breach of NetComm’s Code of Conduct, policies or the law. Matters which should be reported under this Policy, whether actual or suspected may include:

• Dishonest, fraudulent, corrupt or unlawful conduct or practices.

• Misleading or deceptive conduct, including conduct or representations which amount to improper or misleading accounting or financial reporting practices.
• Conduct or any proposed conduct, bid, proposal, offer, contract, product or other aspect of NetComm business that breaches the provisions of any Australian legislation (Commonwealth or State) or in countries NetComm does business.
• Coercion, harassment or discrimination by, or affecting, any member of NetComm or its affiliates.
• A breach of NetComm polices or Code of Conduct.
• Conduct within NetComm control which is significant danger to the environment.

• Conduct endangering the health and safety of any person or persons which has been reported to management but not acted upon.
• Any action taken against, or harm suffered by a person or their family members as a result of making a report under this Policy.
• Any other conduct or act which may cause loss to NetComm or which may otherwise be detrimental to its interest.

Whistleblower: Any NetComm past or present employee, director, contractor or consultant who, whether anonymously or not, makes, attempts to make or wishes to make a report in connection with Misconduct and where the whistleblower wishes to avail themselves of protection against reprisal for having made the report.

Whistleblower Protection Officer (WPO): A designated NetComm representative tasked with the responsibility of protecting and safeguarding the interests of whistleblowers within the meaning of this Policy. The WPO will have access to independent financial, legal and operational advisors as required. The WPO for NetComm: Chief People Officer and the Company Secretary.

Whistleblower Investigations Officer (WIO): A designated NetComm representative tasked with the responsibility of conducting preliminary investigations into reports received from a whistleblower. The role of the WIO is to investigate the substance of the complaint to determine whether there is evidence in support of the matters raised or, alternatively, to refute the report made.

The WIO will be appointed by the WPO on a case by case basis, depending on the nature of the report. The WIO will be an independent party who is not associated with the area under investigation.

The WIO may be a manager once removed from the Whistleblower as long as they are not implicated in the report. Other resources within the group or externally in need can be engaged including People & Culture.

All NetComm employees, directors, contractors and consultants are encouraged to report Misconduct that they believe constitute a breach of NetComm Code of Conduct, policies or the law. Examples of matters which should be reported under this Policy, whether actual or suspected are outlined under the heading Misconduct.

Internal Reporting

Whistleblowers may wish to discuss the matter informally with their direct Line Manager or the People & Culture Manager first in order to determine whether an incident of Misconduct has occurred. At all times, discussions will remain confidential.

External reporting

Alternatively, the whistleblower may report Misconduct, anonymously if preferred, to NetComm’s external independent whistleblower service, FairCall. This service is conducted and managed by KPMG. FairCall reporting options include:

Calls will be received by KMPG FairCall on recognised business days between 8am and 7pm(AEST). Outside these times are diverted to a mobile. In the unlikely event that the calls are not answered by the mobile, a voicemail service provides the ability to leave details. Calls are not recorded. The operators taking the call on this hotline are not associated with NetComm. They are trained, and experienced specialists dedicated to dealing with whistleblowers and their concerns. Whistleblowers will be provided with a confidential reference number by the FairCall operator.

The FairCall operator will prepare a FairCall report which details the Misconduct as reported by the whistleblower. All FairCall reports will be forwarded to the Audit and Risk Committee of the Board for action or referral to the WPO.

All reports under this Policy are treated very seriously and will be investigated appropriately.

Anonymity

If requested, the identity of the whistleblower will be kept strictly confidential by the WPO, WIO and Fair Call unless:

• The person making the report consents to the disclosure.
• The disclosure is required by law.

Protection

A whistleblower that reports matters on reasonable grounds will not be penalised or personally disadvantaged because they have reported a matter. NetComm will not tolerate any instances of legitimate whistleblowers being:

• dismissed;
• demoted;
• subjected to any form of intimidation, harassment and persecution; or

• discriminated against.

A whistleblower who believes they , or their family, has been the victim of any of the above by reason of their status as a whistleblower, should immediately report the matter to the WPO. Where an incident of this nature occurs, the NetComm Anti-discrimination and Equal Opportunity Policy will apply.

Any NetComm employee, director, contractor, partner, supplier or consultant who is found to have dismissed, demoted, intimidated, harassed, or discriminated against a whistleblower by reason of their status as a whistleblower, will be subjected to disciplinary measures. A whistleblower who has been involved in the reported Misconduct may be provided with immunity or due consideration from NetComm initiated disciplinary proceedings, by agreement with NetComm. NetComm however, has no power to provide immunity from criminal prosecution.

Support and Communication

Where possible, and where the whistleblower has chosen to disclose their identity the whistleblower will be kept informed of the outcome of the investigation of his/ her report, subject to privacy and confidentiality considerations. All whistleblowers must maintain confidentiality of all such reports and not disclose details to any person.

Additional support will be provided to the whistleblower with access to counselling support provided by a third party, if requested.

False Reports

Whilst not intending to discourage whistleblowers from reporting matters of genuine concern, whistleblowers must ensure as far as possible, that reports are factually accurate, complete, from firsthand knowledge, presented in an unbiased fashion (and any possible perception of bias of the whistleblower is disclosed), and without material omission.

Where it is established by the WIO that the whistleblower is not acting objectively on reasonable grounds , or they have made a false report of Misconduct (including where the allegation has been made maliciously, vexatiously or without any basis), then they will be subjected to disciplinary proceedings, which may include summary dismissal.

Document Retention and Confidentiality

All information, documents, records and reports relating to the investigation of a reported misconduct will be confidentially stored and retained in an appropriate and secure manner.

KPMG Privacy Statement

This service is provided by KPMG Australia. This service is an independently monitored, external, anonymous service for you to report concerns of possible fraudulent or unethical behaviour relating to NetComm Wireless. If your matter does not relate to such issues, please contact NetComm Wireless directly.

Where KPMG Australia collects personal information as part of this service, it is provided in accordance with KPMG Australia’s Privacy Statement.

Link: www.kpmg.com/AU/faircallprivacy

Publication of Policy

A copy of this policy is available at www.netcomm.com and employee intranet.