Gerry Cuffe Financial Services Limited Employee Handbook Ver 3 Jan 2022

• Sport or Branded Polo Shirts • Short skirts • Shorts • Sports wear • Runners, flip flops • T-Shirts • Low cut tops, halter neck tops, see through tops, tank tops or tops with spaghetti straps Midriff length tops. • Any item with visible logos or emblems. Please note that this list is not exhaustive. Definition of Casual Business Attire: Casual business attire is permitted on days where management approval for same has been granted, for example as part of a Company event or charity project, etc. On these days’ employees can choose to wear more casual clothing that is appropriate to our workplace. Although, employees have an opportunity to dress in more informal wear, it is important that we continue to present a professional image towards members, clients, and the public. This is a difficult area to be absolute about, particularly as fashions change, however, we would ask employees to use their best judgement, common sense and good taste when deciding what to wear on Business Casual days. If you question the appropriateness of the attire, it probably is not appropriate. Let common sense prevail. Appropriate casual business attire includes: For men: • Casual slacks • Neat jeans • Polo shirts (Smart – non Sport or Branded) • Runners • Casual shirts For women: • Casual trousers/skirts • Neat jeans • Casual shirts • Polo shirts (Smart – non Sport or Branded) • Cardigans/sweaters • Runners Unacceptable casual business attire includes: • Tracksuits, combats • Short skirts • Shorts • Football jerseys 100 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• Flip flops • Low cut tops, halter neck tops, see through tops, tank tops or tops with spaghetti straps. • Midriff length tops • Any item with offensive visible logos or emblems Please note that this list is not exhaustive. General professional appearance guidelines: • Hair should be neat and tidy. Non-traditional hair colours are not permitted. • Male employees should be clean shaven. Sideburns, moustaches, and beards should be neatly trimmed. • Regular use of a deodorant is recommended. • No employees will be permitted to wear piercing in any visible part of the body. • Appropriate standards of oral hygiene should be observed before commencement of work and after breaks. Further information on the health benefits of good oral hygiene can be found at www.dentist.ie • Other than for the wearing of traditional earrings, visible piercings or studs are not acceptable during work hours. • Tattoos should be covered while at work. • Jewellery should be kept to a minimum and should be appropriate to business attire. • Where make-up is worn, it should not be to excess. • Footwear should be clean, polished, and well maintained. • Shirttails should be tucked in. • Company logo clothing items must be impeccably maintained. • All clothes should be clean, ironed, and neat. • If an employee leaves the organisation, all uniforms must be returned on last day where they will be professionally cleaned and put back in stock. Failure to return the full corporate wardrobe could result in a deduction from your final salary, which could be as much as €600. • All staff must dress appropriately for work at all times, including casual days. As a staff member, the responsibility is yours to ensure that the wardrobe is worn correctly, and that you present yourself professionally and in accordance with the dress standards above. Failure to do so may result in disciplinary procedures. • Managers have a responsibility to ensure the wardrobe is worn correctly and/or dress standards are met. When standards are not followed, and a staff member does not observe the accepted standard of dress, the manager should remind them of the acceptable standard of dress and personal appearance and why it exists. • Management has the right to review the above as necessary. 101 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 10: POLICY ON DEALING IN SHARES AND OTHER FINANCIAL INSTRUMENTS 10.1 POLICY. This policy is issued to all EBS Group staff members. Where the policy refers to Staff it includes staff of EBS Head Office and branches, (including Managers and Assistant Managers) staff of EBS Agents & staff of EBS Tied Branch Agents, (including Principals), staff of EBS Limited, and staff of subsidiary companies, EBS Mortgage Finance and Haven Mortgages, as an interim measure. 10.2 INTRODUCTION AND SCOPE Staff should be aware that, by virtue of their employment (or, any connection) within a financial institution, they could come into possession of inside information. Inside information is information of a precise nature which has not been made public, relating directly or indirectly, to one or more issuers of financial instruments (e.g., publicly quoted companies) or one or more financial instruments which, if it were made public, would be likely to have a significant effect on the price of those financial instruments or on the price of related derivative financial instruments. The laws and regulations on dealing in financial instruments, e.g., shares and other securities, are strict and the sanctions are severe - Insider Dealing is a criminal offence. For that reason and to provide adequate guidance to Staff on our legal and regulatory obligations and ethical standards, we need a clear policy governing the personal dealing of Staff to protect both the individual and the organisation from breaching their obligations. The key obligation contained in this policy is that staff of EBS must not deal in financial instruments when they possess inside information. Financial instruments are defined in the Notes (note 4), which form part of this policy, but for ease of reference we will refer to \"shares\" throughout this policy document. This policy applies to the personal share dealing of all staff (see notes 1 and 2). Any questions about this policy should be referred to Regulatory Compliance. Risk Characteristics The misuse of inside information (insider dealing) is a criminal offence. This policy is specifically intended to: • Protect staff from contravening the law. • Assist staff in demonstrating ethical conduct in dealing in shares. • Preserve the good reputation of EBS and their staff in all its markets. Policy Statement • Staff must not deal or recommend or induce anyone else to deal in the shares or other financial instruments (as defined in the notes) of any company, if they possess inside information concerning that company, whether they are in possession of that information by reason of their employment within EBS, their association with EBS as a Tied Branch Agent or Agent, or otherwise. • All staff are prohibited from dealing or recommending or inducing anyone else to deal in the shares of Allied Irish Banks, p./. c. during its 'Close Periods' (note 5). • All staff must obtain permission before they deal in the shares of Allied Irish Banks, p./. c. • Under this policy, any such permission to deal must be obtained in writing from the relevant Management Team member and must if granted, be exercised, and executed within 5 102 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

business days of being approved. There is an onus on the staff member to retain the record of permission granted. EBS will retain the copy for a period of 5 years. • Staff must not disclose inside information to any other person unless such disclosure is made in the normal course of the exercise of their duties. • Staff are prohibited from engaging in personal account dealing which may endanger or adversely affect the business or the reputation of EBS, or which may conflict with or interfere with the performance of their duties, or which may result in a breach of any duty to customers of EBS. • Staff personal account dealings in AIB shares must be through a recognised and authorised stockbroker and staff must be in a position to meet all their obligations under such transactions. • Staff must confirm, when requested, that they have read, understood, and agree to comply with this policy. • Failure to observe this policy will be regarded as serious misconduct and could constitute grounds for disciplinary action. Exclusions There are no exclusions to this policy. Staff should seek the advice of Regulatory Compliance on any issues of doubt in the application of this policy. NOTES to Staff Share Dealing Policy 1. Personal dealing means dealing by staff on his/her own behalf or their dealing on behalf of or through another party. 2. Dealing - in the context of this policy, means buying, selling, subscribing for, or underwriting shares, or offering or agreeing to offer shares, either as a principal or as an agent, or inducing or attempting to induce others to so do. It includes entering into a contract (including a Contract for Differences) the purpose of which is to secure a profit or avoid a loss by reference to fluctuations in the price of any shares of a company (e.g., spread betting - which must be through an authorised intermediary). It includes the transfer of shares to a non-connected party. 3. Permission to deal, when required, may only be granted by a member of Management Team and must be in writing or electronic form. 4. Shares and Financial Instruments mean: • shares in companies and other securities equivalent to shares in companies, • corporate bonds and other forms of securitised debt, which are negotiable on the capital market (e.g., the Irish/London Stock Exchange); • any other securities normally dealt in giving the right to acquire any such transferable securities by subscription or exchange or giving rise to a cash settlement, excluding instruments of payments; • financial-futures contracts, including equivalent cash-settlement instruments; • equity swaps; • options to acquire or dispose of any instrument falling into these categories, including cash settlement instruments — this category includes, in particular, equity options; • derivatives on commodities; • spread betting and Contracts for Differences (CFDs) on any instrument falling into these categories; and contracts involving any related indices. 103 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• any other instrument admitted to trade on a regulated market in an EU Member State or for which a request for admission to trading on such a market has been made. 5. 'Close Periods' All staff are prohibited from dealing (or recommending/inducing anyone else to deal) in AIB financial instruments (including shares and other securities) in advance of the publishing of its respective annual or interim financial results. The publication dates of financial year-end or half year-end results vary from year to year and staff should be careful to inform themselves of the publication dates. This is called the ‘close period’. 10.3 EBS INFORMATION SECURITY SUMMARY POLICY The EBS Group (\"the Group\") is committed to protecting information and information systems from unauthorised access, use, disclosure, disruption, modification, or destruction. The Group Information Security policy along with the Information Security Procedures document aims to formalise and document the processes within the Group for information security management. Information security, within the Group, is principally concerned with ensuring that: • Information will be protected against unauthorised access. Employee authority to access information will be limited to the information that they need to fulfil their roles & responsibilities. Employees do not have authority to access information outside of their roles, even should such information be available. • Integrity and confidentiality of information will be maintained. All inbound or outbound emails that contain sensitive data must be password protected. • Internet and external email use is provided primarily for business purposes and its use will be monitored. • Information Security regulatory and legislative requirements will be met. • Business continuity plans will be produced, maintained, and tested for all areas of the business. • A clear desk policy will be maintained. All confidential and restricted information will be securely locked away at the end of each day. • Information security training will be available to all employees. • Business requirements for the availability of information and information systems will be met. • Only spokespersons approved by EBS Senior Management may make statements to the media on behalf of the Group. • Staff identity badges and visitor badges are worn visibly at all times inside the EBS buildings. Staff identity badges must not be visible or worn outside the branch office. • All breaches of information security, actual or suspected, will be reported to, and investigated by the Head of Information Security. Any investigation that shows that a breach of confidentiality has occurred will result in disciplinary action. Other security policy documents are developed for specific functions such as internet use; use of email; use of EBS hardware, software, and network functions etc. These items and more detailed descriptions of our policies are contained in the EBS Information Security Standards document which supports and qualifies this high-level policy. These are summarised in the Information Security Key Policies and Procedures document. 104 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

10.3.1 Responsibilities. Overall responsibility for managing the information security policy will be performed by the Head of Information Security. This includes direct responsibility for maintaining the policy and providing advice and guidance on its implementation. All managers and agents are directly responsible for implementing the policy within their business areas and for adherence by their staff. It is the responsibility of each employee to adhere to the policy and be familiar with the Information Security Procedures document and to inform management of known breaches of the policy. Failure to do so will be deemed misconduct and could result in disciplinary action up to and including dismissalfor cases of gross misconduct. Your attention is drawn to specific breaches of the policy which will result in disciplinary action, and these are identified in the procedures: Section 11.2 — Visitor Controls Section 11.3 — Use of EBS Facilities Section 11.5.1 — Voicemail Section 11.5.3 — USB Keys / Memory Sticks / Removable Disks Section 11.5.4 — Use of Radio Section 12.1.3 — Remote Access Compliance 10.3.2 Approval. The Head of Enterprise Risk & Head of Information Security for EBS d.a.c reviews the Policy and procedures document on an annual basis which is presented to the Operations Management Committee (OMC) of EBS for approval. In addition, material changes to the Information Security Policy are Board approved on an annual basis. 10.3.3 Support Documentation. The Information Security Policy is supported by a number of more detailed policy and procedures addressing specific risks which are attached below. 105 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 11: INFORMATION SECURITY SUPPORT POLICIES 11.1 BUILDING ACCESS CONTROL It is important that only authorised persons gain access to controlled areas within EBS premises and that such entry is recorded both from a security and health and safety perspective. To do otherwise could put at risk — • the personal safety of individuals (especially in times of emergency), • the property we own, (personal as well as company), and • the information we hold and use (e.g., unauthorised disclosure, theft, denial of use of systems etc). Identity (Id) Cards (including Temporary Id Cards and Visitor Passes) must be worn and be visible at all times while on EBS premises. Staff should use their own ID Security swipe to gain access to the building. If your ID Card is lost or stolen report it immediately to Information Security. It is important that all staff assist this endeavour by displaying your badge clearly at all times. 11.2 VISITOR CONTROLS Visitors are defined as people who are neither an EBS employee nor a member of another EBS Company co-located at EBS premises. Agents, temporary personnel, and contractors who have not been issued with a personal EBS Id card must be treated as if they are visitors with regard to being granted access to EBS premises. Personnel hosting the visitor(s) must: • Collect/return your visitor(s) from/to the Security/reception desk. • Escort the visitor(s) at all times whilst on EBS premises. • In the case of a building evacuation, look after the personal safety of your visitor(s) and account for the visitor(s) to your Fire Warden (listed in each department). Under no circumstances is anybody from outside of EBS allowed connect their PC\\Laptop to the EBS network. Any third parties requiring access will be provided with necessary EBS configured IT systems as approved by Information Security. If you have any visitors that wish to transfer data/information to the EBS network, you must schedule a review of the transfer device with Information Security preferably prior to the arrival of the visitor. Only after this review may Information Security give authorisation for the device be used in EBS. A breach of this control will be deemed misconduct and could result in disciplinary action up to and including dismissal for cases of gross misconduct. 11.3 USE OF EBS FACILITIES Facilities such as PCs and email are to be used for EBS related business purposes. While reasonable personal use is permitted, you must bear in mind that such use is monitored, and privacy is NOT guaranteed. Assets in this category include, but are not restricted to, the following: • Email systems — both internal and external (Internet) email. • Computer systems (hardware and software). • Photocopiers. 106 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• Fax. • Phones. • Personal Digital Assistants (PDAs). Effective communication requires that facilities remain available for legitimate business use. Unauthorised personal uses of these facilities will not only incur unnecessary costs, could also lead to denial of business access to such services, may be deemed misconduct and could result in disciplinary action up to and including dismissal for cases of gross misconduct. 11.4 CLEAN DESK GUIDELINES Before leaving your place of work for the day you should ensure that your work area (i.e., work surfaces) is cleared of all papers, files, and media, and that all Confidential and Restricted information is secured. You should; • Remove all papers, folders, reference material and electronic media (e.g., diskettes, tapes etc.) from the top of your work area and place them in provided storage facilities (e.g., desk drawers and filing cabinets) • Ensure that all sensitive information is locked away when not required for immediate use. • Log off and power off PC's when you are leaving for the day. • PC screen saver with password protection MUST be used where available. • Ensure that other company assets (e.g., laptop PC's, mobile phones etc.) are securely locked away. • Any paper documents for disposal and which might be confidential or carry personal customer information should be disposed of in the red (confidential) bins provided for paper. (The contents of all such bins are shredded). At all times, and particularly outside normal working hours, it is essential that EBS protect its information and that of its customers and third parties from unauthorised disclosure and theft. This also applies to safeguarding against theft of company property. • An untidy work area poses potential risks to the health and safety. It is also a fire hazard and hinders cleaning of office areas. Failure to comply with these procedures could harm EBS's reputation and may damage our ability to retain and build our business. 11.5 EQUIPMENT SECURITY 11.5.1 Voicemail. Voicemail, like e-mail, is subject to monitoring by EBS at any time, with or without prior notification. Authorised EBS personnel may review any messages sent or received via the EBS voice-mail system, whether of a business or personal nature, at any time. Any information contained in voice-mail messages may be used and revealed to the appropriate authorities, both inside and outside EBS, to document employee misconduct or criminal activity. You Must Not: 107 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

 Leave abusive, threatening, or inappropriate voicemails on either internal or external voicemail systems.  Leave a voicemail greeting which may be seen as offensive by people both within EBS and those outside the company. A breach of this policy will be deemed misconduct and could result in disciplinary action up to and including dismissal for cases of gross misconduct. 11.5.2 Mobile Phones. Be considerate of others when using your mobile phone in the office. Please  Speak quietly at all times.  Ensure the phone is switched to silent when in the office.  Do not answer the phone when attending meetings. Switch it off or divert calls to voicemail before the meeting begins.  If the device is lockable with a pin number, use it. Also do not make the pin number something easy to crack (for example: 1 2 3 4).  Mobile should not be visible at your work desk or visible when interacting with customers. You should Not:  Use your phone camera in the office.  Leave your phone unattended.  Use your mobile phone when driving a car. This is illegal & dangerous both to you and those around you. If you have an emergency and need to use the phone, pull off the road, stop your vehicle, and if necessary, put your hazard lights on, and then make your call. 11.5.3 USB Keys/Memory Sticks/Removable Disks. These devices are very convenient for transferring data and files from one computer to another. They can store large amounts of data and files. They are also a prime source of virus infections and other malware which are programmed to run automatically as soon as they are connected to a computer. NEVER connect these devices to an EBS PC — even just for battery charging purposes - unless prior approval has been received from Information Security. This will normally involve a scan of the device. Once the device has been used on a non-EBS PC, the approval lapses and the process must be repeated. You must not plug iPods or MP3 players into the USB port of an EBS PC. You may think that you will only charge the batteries but once you connect them to an EBS PC you may unwittingly upload a virus or other malware. This poses a serious threat to the integrity of the EBS network and therefore any transgression will be treated as a very serious breach of policy and will be dealt with accordingly. A breach of this policy will be deemed misconduct and could result in disciplinary action up to and including dismissal for cases of gross misconduct. 11.5.4 Use of radio on EBS Premises. The Copyright Act, 1963 specifies that music cannot be publicly performed without the permission of the owners of the copyright. The courts in Ireland have deemed places of work to be public places. Therefore, playing music from a personal radio on EBS premises — unless confined to earphones — is 108 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

an infringement of the copyright law and is regarded as a criminal offence. Personal radios must not be used on EBS premises. Clarification: Listening to radio broadcasts such as budget reports, election results etc. is not in breach of the law. But if music is being played for the benefit of staff and/or others, then it is regarded as a criminal offence. A breach of this policy will be deemed misconduct and could result in disciplinary action up to and including dismissal for cases of gross misconduct. 11.5.5 Personal Care Electrical Appliances. Any portable appliance such as a hair curler/straightener or a toothbrush charger, etc should be approved before being used in the building. 11.5.6 Sending and Receiving Faxes. When sending and receiving faxes, in or outside of the office, please follow these simple guidelines: • All faxes should be sent with our standard cover sheet containing the confidentiality clause. This cover sheet is available in the Information Security section on Roadrunner. • Ensure that the correct fax number is dialled. • Consider who may read the fax on receipt. • Fax the document yourself, watch the whole transmission and wait for the transmission record (if available). • Be aware that the telephone number you send to may be recorded by the hotel etc. • Keep the original fax and transmission record. • Be aware of the value of the information contained in the fax document. Agree a time with the sender of a fax and wait by the fax machine for receipt of the fax. If it has to be re- transmitted due to failure keep all copies. If necessary, wait until back at an EBS office before disposing of unwanted pages. • Check the location of the receiving fax machine; is it in an open area (e.g., general office, open plan environment). It is essential that EBS protect its information and that of third parties from unauthorised disclosure and theft. Failure to comply with this notice could harm the reputation of EBS and may damage our ability to retain and build our business. 109 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 12: REMOTE ACCESS SECURITY POLICY 12.1 SCOPE. This policy and procedures required to minimise the security risks associated with staff use of EBS remote access devices. It also covers the use of personal laptops and desktop PCs used for the purpose of remotely connecting to EBS systems. • Remote Access Devices are defined as any device that allows inside access to the EBS Computer Network from a remote location using the public Internet. Such devices include: • EBS Laptops/Desktop PC's or non EBS Laptops/Desktop PCs. EBS policy is to prevent unauthorised access to our network. This policy applies to the following: • Laptop computers owned by EBS. • Personal laptop/computers authorised for remote access to EBS systems. • Desktop computers issued by EBS for the purpose of remote access; and • Desktop computers issued by EBS for the purpose of teleworking. The policy applies to all EBS Staff using both laptops owned by the EBS Group and remote access enabled devices which are personally owned by EBS personnel and authorised for access to EBS systems. User Responsibilities: • Defines the policy statements to which the user must agree in order to be issued with an EBS laptop. IT Responsibilities: • Defines the steps taken by IT to protect the Group's asset — both physical and information — as well as restricting access to inappropriate material (these are held by the IT department). Peripheral devices are prohibited from connection to laptops and desktop PCs unless explicit approval has been received from Information Security. In particular no USB devices can be connected unless they are EBS encrypted and approved for use by Information Security. 12.1.1 Objectives. To protect the Group's property and information assets. To ensure that the EBS staff member issued with a laptop assumes an appropriate level of responsibility of EBS Property. Remote access enabled users must also ensure that their home laptops, desktop PCs etc. are appropriately secured. To ensure laptop computers are maintained in a secure environment to minimise the threat level of loss or theft of the device itself and any sensitive information. To ensure compliance with legal obligations, with data protection act, copyright, etc. 12.1.2 Remote Access Security Risks. There are a number of security risks associated with remote access, these include: Confidentiality — This is concerned with the prevention of unauthorised access. 110 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

Integrity — Deals with the accuracy of data and prevents illicit modification. Availability — Ensures that data is backed up and available on demand. There also exists the prevalent risk of theft of the portable device itself. For this reason, remote access tokens must be stored separately from the portable devices. 12.1.3 Remote Access Compliance. It is the responsibility of each remote access device user to adhere to this policy and to inform management of known breaches of the policy. Failure to do so will be deemed misconduct and could result in disciplinary action up to and including dismissal for cases of gross misconduct. Where laptop/desktop PCs are provided with remote/Citrix access to EBS systems it is the user's responsibility to ensure that no data is copied between the Citrix shared drive and the local hard disk of the remote device. End users must operate from the network share drive only. 12.1.4 Stakeholders Responsibilities. The following are the key stakeholder responsibilities: Senior Management Senior management must authorise the issue of all EBS laptops. The purchase and issue of such laptop computers will only occur where a strong business case is made and approved for each individual case. A log of all laptops and remote access devices must be maintained and monitored by IT. A review of these remote access devices is required at least annually. Employee Responsibilities EBS laptop usage is restricted to business purposes only. The information stored on the remote access device must be suitably protected at all times. Where remote access devices are used to store or process sensitive information, they must be equipped with appropriate safeguards to maintain adequate security. These measures must include backup procedures and appropriate encryption/password protection. EBS laptops, remote access devices must not be used to access the Internet except when authorised and through the EBS firewall. Health and Safety Users of remote access devices must accept the fact that the Group will not be liable for any health and safety issues pertaining to keyboard and display limitations on personally owned IT equipment. Responsibility for Physical & Technical Security Users must be aware of and accept the terms and conditions of use, including responsibility for the security of information held on such devices. Where personal laptops have been approved for remote access to EBS systems, it remains the user's responsibility to ensure that up to date Anti-Virus/Anti Spyware software is in place. EBS reserves the right to perform IT health checks on remote access devices and withdraw access where security is deemed to be inadequate. Laptops issued to EBS Staff members remain the property of the EBS. When a laptop is issued to a staff member, the staff member assumes temporary custody of the laptop. 111 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

Should a staff member no longer require access to the laptop for a prolonged period of time (e.g., annual leave) they are advised to return the laptop to EBS for secure storage. Upon leaving the employment of the EBS, the staff member must return the remote access device (where owned by EBS), including any secure access tokens and/or peripheral devices, to IT Services. This releases the staff member from the custody of the remote access device. Travelling with EBS Laptops Persons who are using remote access enabled laptops and who travel for business purposes must be conscious of the information security issues relating to the laptop and implement the appropriate safeguards. At a minimum: • The laptop must not be left unattended in a public place. • When travelling the laptop must always be carried as hand luggage if so, permitted by the airline etc. • The laptop must not be left unattended when powered on, except where the screen is 'locked' by password protection. • Always enable power on password to provide an additional security control. Backing up of Data For those personnel in possession of RAS key fobs, remote access to EBS systems is facilitated. All high priority data should be saved to the user's remote desktop/document storage folder. User authentication Appropriate passwords and logon IDs are currently one of the principal means of validating a user's authority to access a computer system. Appropriate password protection is to be used as defined by the Information Security policy. For those users in possession of an EBS laptop if you think that your encryption password has become known to anyone outside the EBS, you are required to inform your manager immediately. 12.1.5 Ownership of Laptops. EBS laptops, associated peripherals and software are the property of EBS and must be treated as such at all times by the custodian. EBS laptops must be returned for periodic inspection when requested by the IT Department. EBS also reserve the right to perform IT health checks on personal laptops and desktop PCs which are used to connect to the EBS network. Use of the equipment must at all times comply with the Information Security Policy and Standards. Use of Non EBS Laptops computers • The use of laptops not issued by the EBS for business purposes, including remote access, is only permitted where explicit authorisation has been received from Information Security. • EBS IT are responsible for implementing the remote access capability. • The use of personal laptops not authorised by the EBS to connect to the EBS network is also strictly prohibited. 112 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

12.1.6 Incident Notification. • It is the responsibility of each employee to adhere to the policy and to inform management of known breaches of the Policy. Failure to do so will be deemed misconduct and may result in an appropriate sanction under the disciplinary procedure. • Loss or damage of a laptop must be reported to Management, IT Services, and the Information Security department. • Where EBS laptops require maintenance/repair, IT must be contacted directly. In circumstances where personal laptops/remote access devices require maintenance you must first confirm that no EBS sensitive data resides on the device before submitting it to any 3rd parties. Remote Access: RAS key fobs • Remote access to EBS systems is provided by RAS key fobs. These items provide access to EBS secure environments. They must be treated in an appropriate manner i.e.; Key fobs must be kept secure at all times. • N.B. Keep RAS key fobs separate from a laptop when it is not in use. They must not be stored within the laptop case itself. If an EBS RAS key fob is misplaced/stolen the end user must inform IT and Information Security immediately. 12.1.7 Remote Access for Third Parties. The EBS policy for granting remote access to the EBS IT Network to Third Parties is as follows: Third Parties will only be allowed access to the EBS Network under exceptional circumstances. The Third Party must apply for approval to the Head of Information Security. A formal review of the Security Measures Imposed by the Third Party will be carried out by EBS Information Security to ensure EBS security standards are met in the areas of: • Physical and Network security. • Access and Administrative controls. • Written Information Security Policy to cover controls; and IT Security Department to regulate controls. Approved access will be implemented by IT in a secure manner with access restricted — VPN etc. Third Party Access will be reviewed by Information Security on a regular periodic basis. 113 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 13: INTELLECTUAL PROPERTY 13.1 INTRODUCTION The Company is committed to a high level of legal and ethical standards in the conduct of our business. It is the policy of the Company to compete fairly in the marketplace. This commitment to fairness includes respecting the intellectual property rights of our suppliers, customers, business partners, competitors, and others, including original equipment manufacturers and other independent service organisations. No Company employee, independent contractor, or agent should steal or misuse the property rights owned or maintained by another. The purpose of this Policy is to help maintain the Company's reputation as a fair competitor, ensure the integrity of the competitive marketplace in intellectual property, and comply with the laws regulating intellectual property and industrial espionage. This Policy applies to all employees, independent contractors, agents, officers, and directors of the Company, its subsidiaries, business units, partnerships, and joint ventures where the Company has a majority ownership position or exercises management control. 13.1.1 The Company’s Intellectual Property. The Company is committed to protecting its own intellectual property, such as information, processes, and technology, from infringement by others. The Company's informational tools are available at our disposal because of significant investments of time and Company funds. If our intellectual property is not properly protected, it becomes available to others who have not made similar investments. This would cause us to lose our competitive advantage and compromise our ability to provide unique services to our customers. The Company's intellectual property includes confidential Company business information, trade secret technology (such as computer software and systems and knowhow related to them), patented inventions and processes, trademarks and service marks, trade dress, and copyrighted works. It is the responsibility of every Company employee to help protect Company intellectual property. It is the responsibility of Company managers and supervisors to foster and maintain awareness of the importance of protecting the Company's intellectual property. 13.1.2 Intellectual Property of Others. The Company also is committed to respecting the intellectual property of others. The rules with respect to intellectual property, including misappropriation of business information and trade secrets (e.g., computer systems, software, and related knowhow) and infringement of patents, trademarks and service marks, trade dress, and copyrights, are complex, so you should seek expert advice from the Company's attorneys to address specific issues that arise with respect to our business. In many instances the Company's attorneys can perform searches for pre-existing patents, trademarks or service marks, or copyrights and help you avoid infringing conduct. Company attorneys also can evaluate business information to help you avoid infringing conduct. While collecting data on the Company's competitors, you are to use legal, ethical resources to prevent the tainting of Company operations with the improper introduction of the proprietary information of third parties. Substantial civil and criminal penalties may be levied against you and the Company for misappropriation of trade secrets that are avoidable through compliance with the Company's policies and consultation with the Company's attorneys. It is not improper to accumulate information concerning competitors, and it is generally not unethical or illegal to make use of the information as part of our business. Indeed, the Company or any other 114 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

business could hardly go on without being able to use information it has developed regarding its competitors in order to analyse the marketplace and make informed business decisions. But care must be taken by all Company employees, independent contractors, and agents to utilise only legitimate resources to collect information concerning competitors and to avoid those actions which are illegal, unethical, or which could cause embarrassment to the Company. When a situation is unclear, employees, independent contractors, and agents should consult with Company management. Company management may in its discretion wish to further consult with the Company's attorneys. Company employees, independent contractors, and agents having confidential information from a former employer may be bound by a nondisclosure obligation to the former employer. The Company expects employees, independent contractors, and agents to fulfil this obligation. Company employees, independent contractors, and agents should refrain from giving their fellow employees, independent contractors, or agents or from using in the Company's business any confidential information belonging to any former employers. The Company does expect its employees, independent contractors, and agents to use all information, which is generally known and used by persons of their training and experience and all information, which is generally known in the industry. 13.1.3 Illustrative Examples. The following are examples of the types of activities that might constitute a violation of the laws protecting intellectual property or the Company's policies. If you encounter a similar situation, you are encouraged to contact Company management for assistance. 1. Copyright Infringement • Installing computer software on more than one computer system without a proper license. • Making or maintaining additional copies of computer software, including providing such copies to customers, without a proper license. • Copying a third-party's documentation, technical manuals, or user manuals without permission. • Downloading information from a subscription database without permission. 2. Trademark, Patent, or Trade Dress Infringement • Adopting or using a slogan, name, or symbol for goods or services that is confusingly similar to a slogan, name, or symbol used by another. • Making or using a process, product, or device that incorporates patented ideas or features belonging to another. • Failing to act upon notice or information that the Company may be infringing a patent belonging to another. • Using an overall look or design that is confusingly similar to the overall look or design of another's product or service and causing confusion in the minds of consumers as to who is the source of the product or service. 3. Trade Secret Infringement • Disclosing to others any information received in confidence from or protected from disclosure by a supplier, contractor, customer, or other third party. • Stealing, soliciting, or using the trade-secret information of another without written permission from the owner of the information. 115 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

DO NOT DIRECTLY OR INDIRECTLY SOLICIT, OBTAIN, OR USE TRADE-SECRET INFORMATION BELONGING TO OTHERS FROM JOB APPLICANTS, NEW OR EXISTING COMPANY EMPLOYEES, INDEPENDENT CONTRACTORS, OR AGENTS, ORIGINAL EQUIPMENT MANUFACTURERS, SUPPLIERS, VENDORS, CUSTOMERS, OR OTHER THIRD PARTIES. IF YOU BECOME AWARE THAT ANY COMPANY EMPLOYEE, INDEPENDENT CONTRACTOR, OR AGENT MAY BE USING OR DISCUSSING TRADE SECRETS OF HIS OR HER FORMER EMPLOYER OR ANOTHER THIRD PARTY IN HIS OR HER WORK FOR THE COMPANY, YOU MUST CONSULT WITH COMPANY MANAGEMENT IMMEDIATELY. 4. Company Trade Secrets • Company officers, directors, employees, independent contractors, and agents should not disclose Company proprietary or confidential information to third parties with whom the Company is doing business, such as suppliers, licensees, or consultants, except as specifically needed for the third party to perform the services or task requested. Such third parties should be provided information only on a “need to know” basis to allow them to perform the specific services or task requested. All disclosure of Company proprietary or confidential information may be made only after a confidentiality agreement has been entered into with the third party. 116 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 14: ANTI – CORRUPTION AND BRIBERY POLICY 14.1 INTRODUCTION It is our Policy to conduct all of our business, honestly and ethically. The company has a zero-tolerance approach to bribery and corruption. GCFS is committed to acting with integrity and professionalism in all our business dealings and relationships and acting lawfully wherever we operate in implementingand enforcing effective systems to counter bribery and corruption. In developing, introducing, and implementing this Policy, GCFS intends to set out the company's responsibilities and all our employees' responsibilities. The aim is to provide information that will inform and guide all employees working for GCFS to recognise, respond, and deal with suspected issues of bribery and corruption in line with the company's Policy and legal requirements. • This Policy relates to the following statutory obligations: • Ethics in Public Office Act 1995. • Standards in Public Office Act 2001. • Criminal Justice Act 2011. • Prevention of Corruption (Amendment) Act 2010. • Protected Disclosures Act 2014. • Companies Act 2014. • Regulation of Lobbying Act 2015; and • Criminal Justice (Corruption Offences) Act of 2018 This Policy should be read in conjunction with the following policies: • Code of Ethics Policy. • Code of Business Ethics Policy. • Procurement Policy. • Other procedures for investigating concerns as set out in our HR policies, e.g., the Dignity at Work Policy, the Grievance Policy, the Disciplinary Policy, and other policies as may be developed from time to time. 14.1.1 Whom must Comply with this Policy. This Policy applies to all employees working for GCFS or on our behalf in any capacity to include: • Directors • Officers • Employees • Consultants • Contractors • Business Partners • Sponsors • Agents • Third-Party Representatives • Seconded Employees • Interns • Agency Employees • Casual Employees • Volunteers • Any other person or organisation associated with us. 117 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

This applies to wherever the employee at any company level or any from the list above is located. 14.1.2 Clarification on Third-Party Representatives Third-Party means any individual or organisation you come into contact with during the course of your work with GCFS. The following and not extensive list provides some further understanding as to who is a Third – Party. • Actual and Potential Client • Suppliers • Distributors • Business Contacts • Agents • Advisors • Consultants • Contractors • Government Departments (including their Advisors, Representatives, and Officials) • Semi-State Companies (including their Advisors, Representatives, and Officials) • Public Bodies (including their Advisors, Representatives, and Officials) • Politicians • Political Parties 14.1.3 Purposed changes to the Law in this area The Irish government published the General Scheme of the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill 2019 on 3 January 2019. When enacted, many of the Fifth EU Money Laundering Directive provisions aim to strengthen EU money laundering and terrorist financing laws. The bill will amend the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, which gave effect to the Third EU Money Laundering Directive and complements the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018, which gave effect to the Fourth EU Money Laundering Directive. 14.1.4 Changes in the Enforcement of Anti-Corruption Regulations The Criminal Justice (Corruption Offences) Act 2018 came into operation on 30 July 2018 and consolidated the Law in Ireland in the areas of anti-corruption and bribery. The Act repealed the Public Bodies Corrupt Practices Act 1889 and the Prevention of Corruption Acts 1906-2010. The 2018 act is part of a suite of measures published by the Irish government in November 2017 to enhance corporate governance, increase transparency, and strengthen Ireland's response to white- collar crime. The main elements of the government's package on the proposed reform on white-collar crime, along with the introduction of the 2018 act, include: • Establishing the current Office of the Director of Corporate Enforcement (ODCE) as an independent company law, compliance, and an enforcement agency to be known as the Corporate Enforcement Authority. In this regard, the General Scheme of the Companies (Corporate Enforcement Authority) Bill 2018 was published on 4 December 2018. Under the proposed legislation, the ODCE will take the form of a commission, as opposed to its current structure as an office within the Department of Business, Enterprise, and Innovation, with the intention that this will provide the organisation with more autonomy and flexibility in the investigation and prosecution of complex breaches of company law. • Piloting a Joint Agency Task Force within An Garda Síochána to tackle white-collar crime. 118 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• Enacting the Criminal Procedure Bill, the revised general scheme for which was published in June 2015. When enacted, it is envisaged that this legislation will streamline criminal procedures to enhance criminal trials' efficiency. • Implementation of the EU Markets in Financial Instruments Directive II (MiFID II) to improve the functioning of financial markets, making them more efficient, resilient, and transparent and strengthen investor protection (the directive was implemented into Irish Law by the Markets in Financial Instruments Regulations (SI 375/2017) which came into operation on 3 January 2018). • Evaluating the Protected Disclosures Act 2014 (Ireland’s whistle-blower legislation) to identify its effectiveness and how it might be improved. 14.1.5 Definitions Corruption: Broadly defined as the abuse of entrusted power for private gain. The corrupt activity can be engaged in by private individuals, public officials, and businesses. Corruption can take many forms, including conflicts of interest, undue influence, and the giving and taking of bribes. Bribery: Offering, promising to give, or accepting any financial or another advantage, to induce the recipient or any other person to act improperly in the performance of their functions, reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. 14.1.6 Key Corruption and Bribery Offences The essential corruption and bribery offences are provided in Part 2 of the Criminal Justice (Corruption Offences) Act 2018 and include the following offences. Active and Passive Corruption: It is an offence to directly or indirectly corruptly offer, give, agree to give, request, accept, obtain, or agree to receive a gift, consideration, or advantage as an inducement to, or reward for or otherwise on account of, doing an act concerning one's office, employment, position, or business. ‘Corruptly’ is defined under the 2018 act and includes acting with an improper purpose personally or by influencing another person, whether: • By means of making a false or misleading statement. • By means of withholding, concealing, altering, or destroying a document or other information; or • By other means. Active and passing trading in influence: It is an offence to directly or indirectly corruptly offer, give, or agree to provide, a gift, consideration, or advantage to induce another person to exert an improper influence over an act of an official concerning the office, employment, position, or business of that person. Similarly, it is an offence to directly or indirectly corruptly request, accept, obtain, or agree to receive for oneself or any other person a gift, consideration, or advantage on account of a person promising or asserting the ability to improperly influence an official to do an act concerning their office, employment, position, or business. Corruption concerning office, employment, position, or business: An employee who directly or indirectly does any act concerning their office, employment, position, or business to corruptly obtain a gift, consideration, or advantage for themselves or any other person, may be guilty of an offence. 119 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

It is also an offence for an employee to use confidential information obtained in the course of their employment to corruptly receive a gift, consideration, or advantage for themselves or any other person. Giving a gift, consideration or advantage that may be used to facilitate an offence under the 2018 act: It is an offence to give a gift, consideration, or advantage to another person where the person knows, or ought reasonably to know, that the gift, consideration or advantage, or a part of it, will be used to facilitate the commission of an offence under the 2018 act. Creating or using a false document: It is an offence to directly or indirectly create or use a document that the person knows or believes to contain a statement which is false or misleading in a material particular, to induce another person to do an acting relation to their employment, to the prejudice of the last-mentioned person or another person. Intimidation: It is an offence to threaten harm directly or indirectly to a person to corruptly influence that person or another person to do any act concerning their office, employment, position, or business. 14.1.7 What you must not Do. It is not acceptable for you (or someone on your behalf) to: • Give, promise to give, or offer payment, gift or hospitality with the expectation or hope that a business advantage will be received or reward a business advantage already given. • Give or accept a gift or hospitality during any commercial negotiations or tender process if this could be perceived as intended or likely to influence the outcome. • Accept a payment, gift, or hospitality from a third party that you know, or suspect is offered with the expectation that it will provide a business advantage from them or anyone else in return. • Accept hospitality from a third party that is unduly lavish or extravagant under the circumstances. • Offer or accept a gift to or from government officials or representatives, or politicians or political parties. • Threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under the Policy; or • Engage in any other activity that might lead to a breach of this Policy. 14.1.8 Facilitation Payments and Kickbacks GCFS does not make and will not accept facilitation payments or \"kickbacks\" of any kind. Facilitation payments (\"kickbacks\" or \"backhanders\" or \"grease payments\") are unofficial payments made in money or in-kind (i.e., products) to officials, following publicly known or widely followed local customs, for services that the payer is legally entitled to receive without making such payment, to expedite the performance of routine government actions. All employees of GCFS must avoid any activity that might lead to a facilitation payment or kickback been made or considered or accepted by us or on our behalf or that might suggest that such a payment will be made or received. Suppose you have suspicions or concerns about any business transaction for goods or services where there are issues concerning what the payment is for or concerns about receipts or any other concerns that you may have. In that case, you should contact the General Manager or a Director of the company. 120 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

14.1.9 Gifts, Hospitality, and Expenses The Policy allows for all reasonable and appropriate gifts, hospitality, or entertainment given to or received in the course of acceptable business activities. This allows for and supports the company in: • Establishing or maintaining good business relationships. • Improving or maintaining our image or reputation; or • Marketing or presenting our products and/or services effectively. The giving and accepting of gifts are allowed if the following requirements are met: • It is not made to influence the third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits. • It is given in the company’s name, not in your name. • It does not include cash or a cash equivalent (such as gift certificates or vouchers). • It is appropriate in the circumstances, taking account of the reason for the gift; it is timing and value. An example would be the customary exchange of small gifts at Christmas; and • The gift is exchanged openly, not in secret. • It complies with the legal requirements enacted in legislation in Ireland. The exchange of promotional gifts of lower value, such as branded stationery, to or from existing customers, suppliers, and business partners will usually be acceptable; if you have any concerns, please contact your manager. The company offers to reimburse the expenses or receive an offer for a third party to reimburse our expenses, such as the cost associated with attending a business meeting. This would not usually be viewed as bribery. However, where the payment exceeds genuine and reasonable business expenses (such as the cost of an additional night's stay in a hotel), this is not acceptable. The company apricates that practices and customs vary significantly between countries and can also vary considerably with governments. What is acceptable in one country/region may not be acceptable elsewhere. The test to be applied is whether, in all the circumstances, the gift, hospitality, nor payment is reasonable and justified and can be recorded as per the Policy. Another consideration that should be considered is the intention/motivation behind the offer. Is it reasonable and justified and can be recorded as per the Policy, and would it be viewed in Irish society as acceptable in line with the facts of the situation. 14.1.10 Donations GCFS does not make contributions to political parties. However, we do make charitable donations that are legal and ethical under Irish Law and practices. No donation must be offered or made without the prior approval of a manager or a director. 14.1.11 Whistleblowing and Self-Reporting The Protected Disclosures Act 2014 protects a whistle-blower who is an employee when disclosing relevant information. The term 'employee' is broadly defined and includes employees, contractors, self-employed individuals, agency employees, and people on work experience. 'Relevant information' is information that an employee reasonably believes tends to show one or more relevant wrongdoings and came to their attention in connection with their employment. 121 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

‘Relevant wrongdoings’ include: • The commission of a criminal offence. • Failure to comply with a legal obligation. • The occurrence of a miscarriage of justice. • Endangerment of health or safety of an individual. • Misuse of public funds. • Mismanagement of a public body; and • The concealment or destruction of information tending to show any of the foregoing. In order for the protections under the 2014 act to apply, the disclosure must be made through a specified disclosure channel, including disclosures made: • To an employee’s employer. • To a person prescribed by the minister for public expenditure and reform. • To a relevant government minister. • To a legal adviser; or • To a third party (in certain circumstances). The 2014 act requires that the recipient of the disclosure protect the whistle-blower’s identity insofar as possible. A whistle-blower is also protected from penalisation or dismissal by their employer for making a protected disclosure. Further, a whistle-blower will be immune from criminal liability in respect of any offence prohibiting or restricting the disclosure of information if, at the time of making the disclosure, they reasonably believed that it was a protected disclosure under the 2014 act. Self-Reporting Section 19 of the Criminal Justice Act 2011 makes it an offence to withhold information from An Garda Síochána. One knows or believes information that might be of material assistance in preventing the commission by any other person of a relevant offence or securing the apprehension, prosecution, or conviction of any other person for a relevant offence. The relevant offences for the 2011 act are specified in Schedule 1 to the 2011 Act (as amended) and include offences under the Criminal Justice (Corruption Offences) Act 2018. This, therefore, imposes a mandatory obligation on companies and individuals to report suspected instances of bribery and corruption. 14.1.12 Record Keeping and Reporting The Companies Act 2014 governs the requirements in respect of record keeping and provides for offences in respect of non-compliance with record-keeping requirements. The Criminal Justice (Theft and Fraud Offences) Act 2001 makes it an offence to engage in false accounting. All companies operating in Ireland are required to keep accurate corporate books and records under Sections 281 to 285 of the Companies Act. The books and records of a company must: • Correctly record and explain the transactions of the company. • Enable the assets, liabilities, financial position, and profit or loss of the company to be determined with reasonable accuracy at any point in time; and • Enable the directors to ensure that any company's financial statements and any directors' reports must be prepared under the Companies Act comply with the Act's requirements and international accounting standards and can be audited. 122 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• GCFS must keep financial records and have appropriate controls in place to provide evidence and the business reason for making payments to third parties. • All employees must declare and keep a written record of all hospitality or gifts given or received, which will be subjected to management review. • You must submit all expenses claims relating to hospitality or gifts or payments to third parties under our expenses policy and record the reason for expenditure. • All accounts, invoices, and other records relating to dealings with third parties, including suppliers and customers, should be prepared with strict accuracy and completeness. Accounts must not be kept \"off the book\" to facilitate or conceal improper payments or transactions. 14.1.13 Your Responsibility All employees of GCFS must read, understand, and comply with this Policy. The prevention, detection, and reporting of corruption and bribery in any form is the responsibility of all those working for the company or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this Policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with this Policy has occurred or may occur in the future. 14.1.14 Raising a concern. You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage. If you are offered a bribe or asked to make one, or if you believe or suspect that any bribery, corruption, or other breaches of this Policy has occurred or may occur. You must notify your manager or report it per our Whistleblowing Policy as soon as possible. If you are unsure about what is or constitutes bribery or corruption, you should speak with your manager as soon as possible. 14.1.15 Protection Individuals who do not accept or offer a bribe or who raise concerns or report wrongdoing are sometimes worried about possible repercussions. The company is committed to and encourages openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption. This may occur because of reporting in good faith their suspicion that actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered such treatment, you should inform the compliance manager immediately. If the matter is not remedied and you are an employee, you should raise it formally using our Grievance Procedure. 14.1.16 Training and Communication Training on this Policy forms part of the induction process for all individuals who work for the company, and regular training will be provided, as necessary. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and as appropriate after that. 123 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

14.1.17 Breaches of the Policy Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our business relationship with other individuals and organisations working on our behalf if they breach this Policy. 14.1.18 Potential Risk, \"Red Flags.\" The following is a list of possible \"red flags\" that may arise during your employment with the company, which may raise concerns for you under various anti-bribery and anti-corruption legislation. This list is not intended to be exhaustive and is for illustrative purposes only. If you encounter any of these \"red flags\" while working for the company. In that case, you must report them promptly to your manager or the compliance manager or using the procedure set out on the whistleblowing policy: • You become aware that a third-party engages in or has been accused of engaging in improper business practices. • You learn that a third-party has a reputation for paying bribes, or requiring that bribes be paid to them, or has a reputation for having a “special relationship” with foreign government officials. • A third-party insists on receiving a commission or fee payment before committing to sign a contract with the company or carrying out a government function or process for us. • A third-party requests payment in cash and/or refuses to sign a formal commission or fee agreement or to provide an invoice for a payment made. • A third-party request that payment is made to a country or geographic location different from where the third party resides or conducts business. • A third party requests an unexpected additional fee or commission to “facilitate” a service. • Third-party requests/demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services. • A third-party request that a payment is made to “overlook “potential legal violations. • A third-party request that you provide employment or some other advantage to a friend or relative. • You receive an invoice from a third party that appears to be non – standard or customised. • A third-party insists on the use of side letters or refuses to put terms agreed in writing. • You notice an invoice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided. • A third party requests or requires the use of an agent, intermediary, consultant, distributor, or supplier that is not typically used by or known to us. • You are offered a usually generous gift or offered lavish hospitability by a third-party 14.2 REVIEW This policy will be reviewed annually. 124 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 15: CODE OF CONDUCT & EMPLOYEE TRADING POLICY 15.1 INTRODUCTION GCFS is committed to promoting good corporate conduct grounded by strong ethics and responsibility. This Code of Conduct (Code) addresses matters relevant to the Company's legal and ethical obligations to its stakeholders. It may be amended from time to time by the Board of Directors of the Company (Board) and will be provided to all employees of GCFS. This Code applies equally to all Directors, officers, employees, and wherever practicable, to all contractors, consultants, advisors engaged in providing goods or services to GCFS. 15.2 PURPOSE GCFS is entitled to expect the highest professional standards from all contractors, consultants, advisors engaged in providing goods or services to GCFS. Compliance with this Code and GCFS's other policies will ensure compliance with legal responsibilities and will contribute to the good corporate governance of GCFS. 15.3 DISCHARGE OF DUTIES All contractors, consultants, advisors engaged in providing goods or services to GCFS must discharge their duties at the highest levels of honesty and integrity, acting in good faith and the best interests of GCFS, having regard to their position, and GCFS goals and objectives. This entails taking personal responsibility for all issues over which they have control, and for reporting any observed breaches of laws or regulations. It also requires that all contractors, consultants, advisors engaged in providing goods or services to GCFS do not act in ways that would lead others to question their business relationship with GCFS. All Directors will undertake diligent analysis of all proposals placed before the Board, demonstrate commercial reasonableness in decision-making, and will act with a level of skill expected from Directors operating within the financial services sector in Ireland. 15.4 RELATIONSHIPS Performance-enhancing teamwork relies on a workplace where people are treated fairly, are respected by their colleagues, and encourage each other to develop corporately and personally. All contractors, consultants, advisors engaged in providing goods or services to GCFS are responsible for making this happen. The Company is an equal opportunity employer, and discrimination or harassment of any kind will not be tolerated. In dealings both inside and outside GCFS all contractors, consultants, advisors engaged in providing goods or services to GCFS will value integrity, accuracy, conciseness, and timeliness. 15.5 COMPLIANCE WITH LAWS AND ETHICS All contractors, consultants, advisors engaged in providing goods or services to GCFS must respect the laws, customs, and business practices of the Republic of Ireland without compromising the Code. Additionally, all contractors, consultants, advisors engaged in providing goods or services to GCFS must: 125 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

(a) comply with the ethical and technical requirements of relevant regulatory and professional bodies; (b) comply with and promote ethical behaviour; and (c) not engage in conduct likely to bring discredit upon GCFS. 15.6 CONFLICT OF INTEREST All Directors must be independent in judgment and actions, and Directors will take all reasonable steps to be satisfied as to the soundness of all decisions of the Board. In circumstances where personal interests may conflict with those of the GCFS, or its stakeholders, steps must be taken by each Director to eliminate or manage such conflict. Directors and employees of GCFS must disclose to the Board actual or potential conflicts that may or might reasonably be thought to exist between the interests of the Director and/or the employee and the interests of GCFS. Whether an interest is material or not is covered by the materiality threshold set by the Board. The Board can request a director and/or employee to take reasonable steps to remove the conflict of interest. If a director and/or employee cannot or is unwilling to remove a conflict of interest, then the Director and/or employee must absent himself or herself from the room when discussion and voting occur on matters to which the conflict relates. The entry and exit of the Director and/or employee concerned will be minuted by the Company Secretary at a Board meeting. Directors and/or employees are not required to absent themselves when either: (a) the conflict of interest relates to interest common to all employees of GCFS; or (b) the Board passes a resolution that identifies the Director and/or employee, the nature and extent of the Director and/or employee is interest and clearly states that the other Directors are satisfied that the interest should not disqualify the Director and/or employee concerned from the discussion and/or voting on the matter. Gifts or entertainment must not be accepted where the acceptance of the gift could create an obligation on GCFS when negotiations or discussions are ongoing with contractors, consultants, advisors engaged in providing goods or services to GCFS. 15.7 RELATED PARTY TRANSACTIONS Related party transactions include any financial transaction between a director or employee and GCFS and will be reported in writing to each Board meeting. Related party for this process means: (a) a spouse of the Director or employee; or (b) a parent, son or daughter of the Director or employee or their spouse; or (c) an entity over which the Director or employee or a related party defined in (a) or (b) has a controlling interest. GCFS will comply with all legal laws and requirements governing the business of a company engaged in the financial services sector in the Republic of Ireland. 126 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

The Board has also resolved that where a related party makes potential or actual related party transaction applications to a Director or employee of the Company, then the Director or employee shall exclude himself/herself from the approval process. 15.8 EMPLOYEE TRADING POLICY GCFS maintains an Employee Trading Policy (Employee Trading Policy) within a separate document (as distinct from this document) which is included herewith as Appendix A which sets out GCFS’s policies regarding the trading in the A.I.B’s shares. 15.9 CONFIDENTIALITY All contractors, consultants, advisors engaged in providing goods or services to GCFS who have commercially sensitive or otherwise confidential information should not disseminate it to work colleagues unnecessarily. They must not disclose the information to any other person or business without the express permission of EBS HEAD OFFICE to allow the transfer of this information. All contractors, consultants, advisors engaged in providing goods or services to GCFS are prohibited by law from trading in A.I.B shares if they possess commercially sensitive information not released or made known to the regulatory authorities. 15.10 OFFERING PAYMENTS Directors, Officers, and Employees must not: 1. Make an illegal or improper payment on behalf of GCFS to any government agency, person, or entity; and 2. At any time, offer, promise, authorise, approve, or condone the use of corporate funds or property or anything of value: (a) To any government official(s) to influence them to act or fail to act in any official capacity; (b) To any political party, any official of a political party, or any candidate for political office to influence them to act or fail to act in any official capacity; (c) As payment of a “kickback” to obtain business for GCFS. The activities set out in section 15.10 are prohibited by the GCFS even if permitted by the laws, standards, or customs of any prospective client or customer in their home country as normal business activities. This must be followed regardless of any requests or pressures received from any government or the competitive consequences of refusing to comply with such demands or pressures. 15.11 USE OF COMPANY ASSETS GCFS assets are critical to its business and future success; therefore, Directors or employees cannot make personal use of any assets belonging to or owned by GCFS without the express permission of GCFS. 15.12 COMPETITION It is the ambition of GCFS to compete fairly in all its business dealings and operations and not use coercive or misleading practices to secure business opportunities. Furthermore, GCFS commits not to falsify or wrongly withhold information that is relevant to any business negotiation, discussions, or contractual agreements that GCFS enters into. 127 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

15.13 ENVIRONMENT, HEALTH AND SAFETY GCFS and all contractors, consultants, advisors engaged in providing goods or services to GCFS must consider the impact of environmental, health and safety issues when making business decisions and in particular, compliance with enacted laws. 15.14 BREACH OF THE CODE GCFS and all contractors, consultants, advisors engaged in providing goods or services to GCFS are under the obligation to ensure that the Code is not breached. Should a director, officer, or employee of GCFS notice any violations of this Code, they must immediately notify their manager or a member of the senior management team or the Board. If the Director or employee feels they cannot inform their manager or a member of the senior management team or the Board, they must notify GCFS. The reporting of any breaches of this Code will undergo thorough investigation and GCFS will take appropriate actions. Any alleged violation of the Code will be dealt with promptly and in fairness. GCFS ensures that any officer or employee reporting any suspected breach of this Code will not be disadvantaged in any way. GCFS and all contractors, consultants, advisors engaged in providing goods or services to GCFS must not use the reporting mechanism maliciously or mischievously. 15.15 REVIEW OF THE CODE OF CONDUCT This Code will be formally reviewed by the Board each year. 128 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

APPENDIX A: EMPLOYEE TRADING POLICY Purpose This employee share trading policy sets out GCFS policy regarding the trading in A.I.B shares, which includes shares, options, warrants, debentures, and any other security on the issue from time to time. This policy is separate from and additional to the legal constraints imposed by enacted legislation or rules relating to operating in the financial services sector in Ireland. This policy applies to all Directors, senior management, and employees of GCFS and their associates (including spouses, children, family trusts, and family companies) as well as contractors, consultants, advisers, and auditors of the Company. Requirements It is illegal to trade in A.I.B shares while in possession of unpublished price sensitive information concerning A.I.B. Under the Corporations Act, a person with inside information must not either alone, or with another person, to deal in the shares in a company or enter into an agreement to trade in the shares of the company. Inside information is defined as information that: • is not generally available; and • if generally available, a reasonable person would expect it to have a material effect on the price or value of the shares in the company. General Prohibition on Insider Trading All Directors, Officers or employees are prohibited from trading in A.I.B shares while in possession of unpublished price sensitive information concerning the company. In addition, while in control of unpublished price sensitive information all directors, officers or employees must not advise others to trade in A.I.B shares or communicate the information to another person knowing that the person may use the information to trade in, or procure someone else to trade in, A.I.B shares. Unpublished price sensitive information is information regarding A.I.B shares, of which the market is not aware and that a reasonable person would expect to have a material effect on the price or value of A.I.B shares, and includes: • A proposed significant acquisition or disposition; • Drill or exploration results; • A significant business development or a proposed change like the Company business; • Details of material contracts that are being negotiated by the Company; • Potential litigation that would have a substantial effect on the Company; • A proposed change in the share capital structure of the Company; • A proposed change in A.I.B ’s dividend policy; and • A significant change to the Board or senior management Restrictions on Trading All parties to which this Employee Trading Policy applies are prohibited from trading in A.I.B shares at any time when they are in possession of any unpublished price sensitive information or potentially price-sensitive information. The prohibited trading period to which this Employee Trading Policy applies is any periods where parties are in possession of any unpublished price sensitive information or operation information and any other period communicated by the Board from time to time. 129 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

If any party the subject to this Employee Trading Policy is in any doubt as to the possession of price- sensitive information or potentially price-sensitive information they are required to seek permission from the Board of GCFS (or in the case of the Managing Director, the Chairman) before trading in the A.I.B shares. Should the application of this Share Trading Policy conflict with any enacted legislation such as the following: • Part V of the Companies Act, 1990. This applies to companies listed on the Alternative Securities Market and the Irish Enterprise Exchange of the Irish Stock Exchange, so should not • be of wide application; • Market Abuse (Directive 2003/6/EC) Regulations 2005 SI No. 342 of 2005, (“the Regulations”). And Part 4 of the Investment Funds, Companies and Miscellaneous Provisions Act, 2005, (“the Act”). • Market Abuse Rules issued by the Financial Regulator (“the Rules”). Where an entity is considering making an offer for a company that is listed on a relevant market, it will need to comply with the following pieces of legislation in addition to those listed above. • The Irish Takeover Panel Act, 1997 (“Takeover Act”), • The Irish Takeover Panel Act 1997, Takeover Rules, 2007 (“Takeover Rules”). • The European Communities (Takeover Bids (Directive 2004/25/EC) • Regulations 2006, (\"Takeover Regulations\"), and Point IX applies to listed companies and requires them to comply with the obligations of the Regulations as if it were an issuer for the Regulations. • Listings Rules (these apply to Companies listed on the primary market of the Irish Stock Exchange). • Section 30 of the Companies Act 1990. Closed Periods 1) Directors and Employees Directors and employees must also not deal in A.I.B shares during the week immediately before and 48hours after; • the release of A.I.B half-yearly or yearly results; • the release of A.I.B quarterly results; or • the Annual General Meeting. 2) Directors and Senior Management Directors and senior management must also not deal in A.I.B shares during the week immediately before and 48 hours after; • the date of the Board meeting for the approval of the Company interim or annual results; • the deadline for the Company to publish its annual results announcement. GCFS may at its discretion vary this rule concerning a particular period by a general announcement to all employees either before or during the period. However, if a director or employee of GCFS has price 130 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

sensitive information that is not generally available to the market, then he or she must not deal in A.I.B shares at any time. Additional Restrictions on Short-Term Trading GCFS encourages Directors and employees to adopt a long-term attitude to their investment in A.I.B shares. Consequently, Directors and employees may not engage in short-term or speculative trading of A.I.B shares. Permission to Trade Designated Officers may trade in A.I.B shares at other times so long as they do not have any unpublished price sensitive information. Chairman Prior to trading in (either buying or selling) A.I.B shares, the Chairman must notify the Managing Director of his/her intention to trade and confirm that he/she is not in possession of any unpublished price sensitive information. Directors Prior to trading in (either buying or selling) A.I.B shares, Directors must notify the Chairman of their intention to trade and confirm that they are not in possession of any unpublished price sensitive information. Employees Prior to trading in (either buying or selling) A.I.B shares, employees must notify the Chairman of their intention to trade and confirm that they are not in possession of any unpublished price sensitive information. The requirement to provide notice of an intention to trade in A.I.B shares does not apply to the acquisition of securities through the Director, officer, or employee share or option plans. However, the requirement does apply to the trading of the securities once they have been acquired. Notification of Trade in Company Shares Directors must also notify the Company Secretary of any trade-in A.I.B shares as soon as practicable, but no later than 5 business days of such trade occurring so that the Company Secretary can comply with the enacted legislation included in this policy and the requirement to notify the regulatory body of any change in interest held by a director. The Company Secretary will maintain a register of all trades and holdings in A.I.B shares by Directors. Breach of Policy 1) A breach of this policy by a Designated Officer (even if the Designated Officer is not a Key Management Personnel) is serious and may lead to disciplinary action, including dismissal in serious cases. It may also be a breach of the law. 2) Insider trading is a serious matter which is a criminal offence. It is punishable by substantial fines or imprisonment or both. 3) Insider trading may also attract civil penalties. A court may impose substantial pecuniary penalties for insider trading and order payment of compensation to persons who suffer loss or damage because of insider trading. 131 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 16: CODE OF BUSINESS ETHICS POLICY GCFS is committed to the highest standards of transparency and business conduct. We act responsibly, based on our Code of Business Ethics. 16.1 INTRODUCTION GCFS is committed to the highest standards of transparency and business conduct. We act responsibly, based on our Code of Business Ethics. We advocate free and fair trade, striving for openand honest competition and ethical conditions within the countries' legal frameworks where we do business. 16.1.1 Purpose The purpose of this Policy is to set common standards for all GCFS business regarding compliance with our zero-tolerance Policy towards any form of bribery and corruption and in compliance with Irish laws and where GCFS conducts business. This Policy links to our anti-bribery and corruption policy and applies to all employees of GCFS. GCFS will strive to fully adopt these principles in all operations in which GCFS has management control. We will also use our influence to promote the principles in other companies that deal with GCFS. 16.1.2 Principles The following principles apply for the activities under this Policy: GCFS has a clear statement against bribery and corruption and does not accept bribery or corruption in any form. At GCFS, we do not offer, authorise, or pay bribes or anything of value to obtain or retain business or to encourage or reward a decision. No GCFS Company employee shall offer, provide, authorise, request, accept, or receive a bribe either directly or indirectly, including through any third party. It is prohibited to contribute financial means to any third party in a way that could constitute negligent financing of corruption. It is essential to make sure that money paid to third parties, for example, to agents, partners, vendors, and consultants, is not used for corruption. Breaches of this Policy are investigated, and necessary precautions and actions are taken to eliminate or mitigate the risk for bribery and corruption concerning third parties. All procurement activities at GCFS are performed in compliance with the Procurement Process, which clearly states the basic principles for a fair selection of suppliers and segregation of duties. 16.1.3 Supplier Code of Conduct The Supplier Code of Conduct includes a strict prohibition for all forms of corruption, including but not limited to extortion, bribery, facilitation payments, nepotism, fraud, and money laundering. At GCFS, we avoid an interest or situation that conflicts or may appear to conflict with our professional duty. GCFS employees are expected to always act in GCFS's best interest and exercise sound judgment, unaffected by private interests or divided loyalties. All employees are prohibited from making or accepting facilitation payments, i.e., payments made to government officials or third-party suppliers, to encourage or ensure that routine procedures are carried out or speeded up. 132 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

GCFS employees can only accept business hospitality and gifts proposals if they are open, reasonable, demonstrate a clear business objective, are appropriate for the nature of the business relationship. GCFS does not allow gifts, apart from branded items of minimal value to public officials. 16.1.4 Administrations or Governing Bodies We do not permit charitable or political donations or sponsorships as a way of concealing a bribe. It is never acceptable to make donations to political parties. We keep accurate and transparent financial books and records. This includes the requirement that gifts and hospitality and sponsorships, and donations are recorded to reflect the nature and purpose of the activity. We also require and keep records of the needed approval documents and verification of third parties. These principles apply as long as they do not place GCFS in violation of domestic laws and regulations. 16.1.5 Breaches Against this Policy Any GCFS employee who suspects violations of The Code of Business Ethics, or this Policy must speak up and raise the issue to their manager or directly to a board member. Speaking up is encouraged when an employee, in good faith, believes they have observed or are aware of a potential violation of The Code of Business Ethics, this Policy, or the Law. 16.2 REVIEW This Policy will be reviewed annually by GCFS. 133 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 17: CODE OF ETHICS POLICY 17.1 INTRODUCTION In GCFS we are committed to being an independent, forthright, and influential organisation with a compelling, clear, and challenging vision of providing financial services to the public, which results in: • Trust by the Public, • Respected by our Peers, and a • Fulfilling Workplace for our People GCFS Code of Ethics (the \"Code\") defines the standards of ethical conduct we uphold. Adhering to these standards ensures that we deliver on our mandate consistently with our Principles and Priority Behaviours. This Code and the various employees' rules referenced herein form part of the employment contract between GCFS and its employees. They take the GCFS Ethics account and reflect the mutual duty of trust and confidence that subsists between the GCFS and its employees. Under GCFS’s Disciplinary Procedure, a breach of this Code or the employee's rules it references may lead to disciplinary action up to and including dismissal. 17.1.1 Standards of Ethical Conduct The Code, while not aiming to cover every possible scenario, sets out six key areas where standards of ethical conduct must be adhered to, namely: • Acting with integrity and prudence • Treating others with dignity, respect, and due care • Avoiding conflicts of interest • Protecting confidentiality and avoiding the misuse of information • Representing GCFS appropriately • Reporting wrongdoing On an on-going basis, all employees are required to take all reasonable steps to comply with this Code and the employee's rules referenced herein and to complete the mandatory annual training in respect of the Code. If you are, at any time, unsure about the interpretation of the standards and what is expected of you. In that case, you should consult your manager to fully understand your responsibilities to ensure you comply with the Code of Ethics. 17.1.2 Act with Integrity and Prudence GCFS performs its duties in a manner that demonstrates its unwavering commitment to integrity, accountability, and honesty. Each employee has an individual responsibility to protect GCFS's good reputation. All employees must refrain from acting in a manner they know, or suspects are illegal, improper, or dishonest. In the conduct of their work, all employees are also required to take all reasonable steps to ensure that GCFS complies with its legal and regulatory obligations. All employees of GCFS should make every effort to manage their personal financial affairs prudently and responsibly. If any employees experiencing significant financial difficulty levels are encouraged to inform GCFS of this via their manager so that they can be provided with the appropriate support and advice. In recognition of public accountability's importance, we actively facilitate openness and transparency regarding how we work. While protecting the right to privacy and actively avoiding the misuse of information, we enable public members to access information concerning the work that we do to the 134 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

greatest extent possible and consistent with the public interest. In this regard, employees should be aware of the GCFS's obligations under the Freedom of Information Act 2014. 17.1.3 Treat others with Dignity, Respect, and Due Care GCFS is committed to maintaining a positive, progressive, and fulfilling working environment where all employees are treated equally and respected for their individuality and diversity. GCFS does not tolerate any form of employee bullying, intimidation, or harassment. All Employees are required to comply in full with the Dignity at Work Policy. Issues or complaints concerning dignity and respect may be raised through the guidelines set out in the Grievance Procedure or a case of perceived bullying and/or harassment by following the procedures set out in the Dignity at Work Policy. GCFS's employees' health and safety responsibilities are outlined in our Safety Statement as well as in the Safety, Health, and Welfare at Work Acts. In summary, employees are expected to exercise reasonable care for their safety and others' safety and report any perceived risk or danger to their manager. 17.1.4 Avoid Conflicts of Interest GCFS aims to safeguard its impartiality at all times by actively avoiding conflicts of interest. A conflict of interest arises when personal, commercial, or political associations or interests inappropriately affect our judgment or actions when performing our duties. GCFS employees must never use or attempt to use their position in the company to obtain any improper benefit for themselves, their family, or others connected to them. They must always seek to avoid not only actual but also potential or perceived conflicts. An extensive range of situations could give rise to actual, potential, or perceived conflicts of interest. In all such circumstances, all employees should avoid such conflicts and contact their manager to obtain guidance and support on how to manage potential conflict. In certain instances where a conflict of interest is identified, GCFS reserves the right to take appropriate measures, such as assigning alternative duties to a member of employees to address the conflict. Outlined below is a non-exhaustive list of the main types of situations in which conflicts may arise and provides clarity concerning GCFS's expectations of employees in such situations: You are receiving or being offered hospitality or gifts. The receipt of gifts or hospitality from third parties has the potential to create a conflict of interest. In order to manage this issue, GCFS has included in the employee handbook details on accepting hospitality and Gifts. GCFS urges all employees who are offered gifts or hospitality to review this entry section 2.10 Gifts, Entertainment & Sponsorship. 17.1.5 Commercial and Private Business Affiliations All GCFS employees should avoid being affiliated with any commercial or private business which may influence, or which could be seen to influence, the impartial discharge of an employee’s duties. Therefore, all GCFS employees should avoid dealing with companies with whom they have family or friendship relations, which could give rise to an actual, potential, or perceived conflict of interest. In such circumstances, at a minimum, the employees should disclose such a relationship to their manager and exclude themselves from relevant decision-making processes. 135 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

An employee's wishing to undertake secondary employment (including occasional or part-time work and any self-employment) must receive prior written approval from GCFS. All employees must discuss their intention to take up secondary employment with their manager, who will, in turn, confirm the outcome of the decision with GCFS. Permission will be declined if, in the opinion of GCFS, the secondary employment is inconsistent with the employee’s role as an employee of GCFS or has the potential to create a conflict of interest. 17.1.6 Political Affiliations GCFS is an independent institution, and all employees should guard its apolitical position at all times. All employees should not engage in any activity, which may, by virtue of their employment with GCFS, call into question this apolitical status or which might result in the GCFS's name being brought into any political or public controversy. 17.1.7 Procurement GCFS employees involved in procuring goods and services on behalf of GCFS should be aware of GCFS’s obligations under European and national procurement legislation when engaging with potential suppliers. All employees’ members are prohibited from engaging in any behaviour that could give rise to conflicts of interest that may impact the integrity of the competitive tender process and are obliged to comply with the rules set out in GCFS's Procurement Policy. Non-adherence to the rules set out in GCFS’s Procurement Policy could expose GCFS to the risk of legal or financial sanctions or litigation and compromise GCFS’s reputation. 17.1.8 Personal Financial Transactions All employees are subject to restrictions on their personal transactions involving certain shares and other financial instruments. All employees are also obliged to disclose their holdings of certain shares and other financial instruments upon joining GCFS. Further details concerning these restrictions are set out in the Employee Trading Policy. It is important to note that all employees are subject to the Employee Trading Policy, regardless of their position within GCFS and their level of access (if any) to confidential information. All employees are also reminded that the Employee Trading Policy is in addition to any obligations they may have concerning the use of insider information under market abuse legislation. 17.1.9 Post-Employment Conflicts of Interest Members of employees who intend to leave GCFS to take up alternative employment, self- employment, or business are required to provide early notification to senior management. When a conflict of interest arises or might be perceived to exist between those duties held in GCFS and those to be undertaken within the new employment arrangement, in such circumstances, GCFS may assign alternative tasks to the individual. At the same time, their notice period is being served. The notice period may be lengthened over the contractual or statutory notice period (by mutual agreement only) where GCFS or the employees consider it appropriate to create a suitable 'cooling-off' period. 17.1.10 Pre-employment Conflicts of Interest All Employees will already have been made aware at the pre-employment stage that all offers of employment by GCFS to prospective employees incorporate pre-conditions to avoid pre-employment conflicts of interest. The pre-conditions require candidates to disclose any actual or potential conflict of interest arising from previous occupational activities or personal relationships so that GCFS can assess whether the conflict is compatible with the role and/or how the conflict may be addressed. 136 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

Where GCFS has determined that it may be possible to address the conflict, the candidate and GCFS will agree on appropriate mitigation measures. If he or she intends to accept the offer of employment, the candidate will be required to take such actions as are necessary to implement such measures. 17.1.11 Protect Confidential Information All GCFS employees have a duty of confidentiality regarding their work and the information they handle and retain. This duty of confidentiality seeks to prevent the unauthorised disclosure and misuse of confidential information in all its forms and to protect the personal data held by GCFS. In general terms, misuse entails deliberately exploiting confidential GCFS information for an employee or an employee’s member’s associate’s personal use, or advising others, based on such information. All GCFS employees' obligations concerning privacy and confidentiality of information are governed by various legislation. Therefore, all GCFS employees are required to ensure that all confidential information about GCFS, its functions, and operations is treated with absolute confidentiality. And to ensure that access to this information is restricted to those employees’ members who need it for the performance of their duties. To prevent accidental disclosure, employees are always expected to keep and safely transfer confidential documents and not to discuss confidential matters in places where they may be overheard. The requirement to preserve the confidentiality of the GCFS's and other non- public information continues indefinitely after an employee's employment with GCFS ends. When leaving GCFS, all employees must return to GCFS, on termination of their employment or role, any property of GCFS which they may have in their control or possession. Protecting confidential information means protecting the integrity and availability of information and the underlying processes, facilities, and IT systems used to manage that information. All employees must ensure that they comply with the relevant information security policies to ensure that access to information is restricted to those who need it for the performance of their duties. Any information that may be considered confidential or commercially sensitive, including communication (commercial or personal) about other employee’s members, GCFS itself, contractors, or third parties associated with GCFS or any information that could be used to gain unauthorised access to the GCFS's information or premises, should not be shared under any circumstances. Where you have any queries or concerns about an information security nature, these should be referred to the IT Department and your manager. If you doubt whether you can share information or what you should do next, the IT Department or your manager will advise you. You must follow all instructions to prevent unauthorised access to confidential information. 17.1.12 Represent GCFS Appropriately All GCFS employees should be aware that the reputation of GCFS can be affected by the conduct of its employees. Courtesy, consideration, and professionalism are expected from all employees. Personal views expressed by employees on social media, or any other public forum should not be linked in any way to GCFS. All members of employees should only engage in public debate (e.g., letter writing to newspapers, contributions to TV or radio programs, etc.) in a personal capacity and in such a manner that does not in any way link their personal views with GCFS. Media related queries received in the course of employee's work should be immediately referred to their manager, and requests for information received from members of the public should also be directed to your manager. 17.1.13 Report Wrongdoing GCFS is committed to encouraging and protecting all employees who raise concerns about breaches of this Code or the employee's rules it references. Therefore, all GCFS employees must report 137 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

concerns of suspected or confirmed wrongdoing whether these have already occurred, continue to occur, or may occur in the future. The Confidential Disclosures ('Whistleblowing') Policy outlines a safe and confidential process for employees to raise concerns. 17.1.14 Know your Responsibilities under the Code. General Responsibilities The Code is binding on all GCFS employees, including when on unpaid leave or secondment. And maybe reviewed, amended, or added to from time to time at the discretion of the GCFS. To ensure on-going adherence to the Code, every employee of GCFS is required to confirm on an annual basis that they are familiar with the contents of the Code, that they understand their obligations under the Code, and that they comply with them. All employees should be aware that this compliance obligation extends to all GCFS employees' rules referenced in the Code. In the case of any doubt, GCFS employees are expected to proactively seek advice on the interpretation of the rules from their manager, to make a full disclosure if they have concerns regarding any aspect of their obligations under the Code. Any actual or suspected instances of non-compliance with the Code will be handled between relevant management and the Human Resources Department, in line with GCFS's disciplinary procedures. Such instances may include any employee's failure to comply with the terms or conditions of his or her employment or with any employees' rules referenced within this Code. All GCFS employees should be aware that the GCFS is required to report breaches of this Code of a certain severity to the appropriate authorities. 17.1.15 Specific Roles and Responsibilities Ownership of the Code of Ethics rests with GCFS. In this context, GCFS assumes responsibility for: • Reviewing and approving the Code, including any proposed amendments or additions, on an annual basis; thereby, determining the corporate and ethics culture within GCFS. • Considering the annual report, prepared by the Compliance Officer, which details the status of compliance with the Code in the previous year. Senior Management: Senior management has the same responsibilities as all other employees in terms of compliance with the Code. In addition, they are responsible for: • Applying the Code within their area of responsibility and fostering compliance by leading by example. • Contributing to the communication of the Code and to raising awareness at the local level; and • Liaising with the Human Resources Department, the Compliance Officer, as appropriate, in the event of actual or suspected breaches of the Code by a member of their employees. The Human Resources Department will assist in addressing such matters where necessary. Management is also required to liaise with the Compliance Officer in agreeing how offers of business hospitality and gifts should be handled and to ensure that a register is maintained to record all business hospitality and gifts accepted in their division. Compliance Function 138 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

The Compliance Officer assumes primary responsibility for: • Monitoring the continued development of the Code vis-à-vis legislation and best practice on an annual basis. • Raising awareness and educating employees. • Steering or contributing to the drafting of local rules. • Ensuring that all employees are reminded on an annual basis of their obligation to be compliant with the Code and for implementing a process to enable all employees to confirm their understanding of the requirement to comply with it. • Conducting, as required, checks on compliance with the Code. • Providing advice and guidance on the interpretation and application of the Code and associated rules (with the support of the Compliance Officer); and Compliance Officer EBS employs a Compliance Officer to provide specialist advice in respect of ethical issues to GCFS and its employees. The Compliance Officer is available to employees’ members to: • Provide guidance and answer any queries concerning the Code. • Assist in defining measures to ensure compliance with the Code and, where breaches of the Code have been made known to them, provide information to the Human Resources Department and relevant management; and • Obtain legal advice (from EBS's Legal Division), as required, to ensure that all matters being dealt with fully comply with the Law. • Employees may contact the Compliance Officer. The Compliance Officer will, insofar as is possible, maintain the confidentiality of individuals. If an employee's identity needs to be revealed, it will be discussed with the person in advance. Human Resources Department The Human Resources Department are responsible for: • Liaising with management and the Ethics Officer concerning breaches of the Code. • Executing the Central Bank’s Disciplinary Procedure as appropriate; and • Supporting divisional management in respect of the management of breaches of the Code. 17.2 REVIEW This Policy will be reviewed annually. 139 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

SECTION 18: DIGNITY AT WORK POLICY 18.1 INTRODUCTION The policy is compliant with the relevant legislation and Codes of Practice. GCFS is fully committed to the principles espoused in our Dignity at Work Charter (Appendix 1). 18.2 POLICY AIM This policy aims to convey GCFS’s position concerning creating a hostility free workplace culture in which each member of staff is valued and enabled to develop to their full potential. GCFS will not tolerate behaviour that may have the effect of belittling another person. Examples of such behaviour include: • bullying, • harassment, • sexual harassment, • derogatory comments, • uninvited physical contact and any other act which creates an intimidating work environment. Employees must be able to carry out their work duties without fear of any unfair treatment. Employees will face disciplinary action up to and including dismissal if it is established, following a properly constituted investigation under this policy, that they have engaged in conduct that meets the definitions of bullying, sexual harassment, or harassment under this policy. Cases of bullying, sexual harassment or harassment against non-employees may result in sanctions such as suspension of contracts, exclusion orders from the GCFS’s premises or any other such sanctions that GCFS deems fit. 18.3 POLICY STATEMENT All employees have the right to be treated with dignity and respect. We are committed to protecting the dignity and respect of all those who work within our Company. In particular, we are committed to ensuring that GCFS is free from any form of bullying or harassment and that our work environment is conducive to providing high-quality service in an atmosphere of respect, safety, and equality. No bullying or harassment within the Company or in connection with the Company's work will be tolerated. Complaints of bullying or harassment may be dealt with either formally or informally or by alternative means, as described below. Complaints by employees or other persons in the workplace of bullying or harassment at work will be treated with fairness, sensitivity, respect and (as far as possible) confidentiality for all parties concerned. Any person accused of bullying and/or harassment will be afforded natural justice and treated with fairness and sensitivity. 18.4 PURPOSE GCFS is committed to creating and maintaining a work environment where employees and contractors are valued and consider themselves free to perform work in an environment free from all forms of bullying/inappropriate behaviour, harassment, and sexual harassment. In accordance with our organisational values, GCFS expects that all employees will conduct themselves with usual standards of courtesy and consideration in the workplace, at work-related events, and when doing business on behalf of the organisation with: 140 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• Colleagues • Clients • Consultants • Contractors • Business Partners • Sponsors • Agents • Third-Party Representatives • Seconded Employees • Interns • Agency Employees • Casual Employees • Volunteers • Any other person or organisation associated with us. Bullying, harassment, and sexual harassment are behaviours that contravene this expectation and will not be tolerated at any level in GCFS. GCFS undertakes that any allegations of bullying/inappropriate behaviour, harassment or sexual harassment will be treated seriously, and that the organisation will do its utmost to ensure that all: • Colleagues • Clients • Consultants • Contractors • Business Partners • Sponsors • Agents • Third-Party Representatives • Seconded Employees • Interns • Agency Employees • Casual Employees • Volunteers • Any other person or organisation associated with us. Will be protected against victimisation for making or being involved in a complaint. GCFS is committed to ensuring that all parties employed by or associated with GCFS are aware of the procedures for bringing complaints under this policy and should not feel threatened or fearful of raising such issues in GCFS. 18.5 SCOPE This policy applies to all employees, whether permanent or fixed-term, full-time or part-time, and irrespective of the length of service, that could be reasonably regarded as an affront to a person’s dignity at work. The policy also applies to: • Colleagues • Clients • Consultants • Contractors 141 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• Business Partners • Sponsors • Agents • Third-Party Representatives • Seconded Employees • Interns • Agency Employees • Casual Employees • Volunteers • Any other person or organisation associated with us. This policy further extends to behaviours that occur outside the GCFS’s premises, such as at social functions or training events, provided there is a link with the work of GCFS and its employees. The protection provided under this policy will extend to: − colleagues, clients, customers, and other business contacts with whom employees can reasonably expect to come into contact within the course of their employment with the Company. − Conferences, training, and any other work-related events that take place beyond the workplace. − Different treatment of an employee because s/he has rejected or accepted the sexual harassment or harassment. GCFS emphasises that individuals themselves decide what behaviour constitutes unwanted or unwelcome behaviour irrespective of the attitude of others to any matters that arise under this policy. GCFS will deal with allegations of bullying, harassment, or sexual harassment confidentially and will do its utmost to protect employees who make a complaint (or become involved in a complaint) from victimisation. GCFS refers all employees to the procedures for bringing complaints under this policy and aims to provide a workplace where no employee feels threatened or fearful of raising a complaint. 18.6 DEFINITIONS 18.6.1 Bullying “Workplace bullying is repeated inappropriate behaviour, direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment, which could reasonably be regarded as undermining the individual’s right to dignity at work”. An isolated incident of the behaviour described in this definition may be an affront to dignity at work, but a once-off incident is not considered bullying. Bullying is inappropriate behaviour that occurs on more than a single occasion and can include, for example; • verbal harassment such as jokes, comments, ridicule, or songs. • Written harassment such as fax, text messages, emails, notices, or social media comments. • Physical harassment such as jostling, shoving or any form of assault. • Intimidatory harassment such as gestures, posturing or threatening poses. • Visual displays such as posters, emblems, or badges. 142 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• Excessive monitoring of work. • Isolation or exclusion from social activities. • Unreasonably changing an employee's job description or targets. • Pressure to behave in a manner that the employee thinks is inappropriate, for example, to dress in a way that offends the employee's religious beliefs. Further examples of Bullying are outlined in Appendix 2. 18.6.2 Harassment Harassment is any form of unwanted conduct related to any of the discriminatory grounds set out in the Employment Equality Acts 1998 to 2015 (the EEA Acts), which has the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment for the person. The nine discriminatory grounds under the EEA Acts are: • Gender. • Civil Status. • Family Status. • Sexual Orientation. • Religion. • Disability. • Age. • Race (including a person’s race, colour, nationality or ethnic or national origins); and • Membership of the Traveller Community. Harassment may consist of a single incident or repeated inappropriate behaviour. Examples of Harassment are outlined in Appendix 2. Examples of conduct amounting to bullying or harassment include but are not limited to: • verbal harassment such as jokes, comments, ridicule, or songs • written harassment such as fax, text messages, emails, notices, or social media comments. • physical harassment such as jostling, shoving or any form of assault. • Intimidatory harassment such as gestures, posturing or threatening poses. • Visual displays such as posters, emblems, or badges. • Excessive monitoring of work. • Isolation or exclusion from social activities. • Unreasonably changing an employee's job description or targets. • Pressure to behave in a manner that the employee thinks is inappropriate, for example, to dress in a way that offends the employee's religious beliefs. 18.7 OTHER FORMS OF INAPPROPRIATE BEHAVIOUR While other inappropriate behaviour may not amount to bullying or harassment under the above definitions, they are also not condoned or tolerated by GCFS. An isolated incident that is an affront to dignity may not be bullying, but it may be inappropriate behaviour. Similarly, harassment on a ground that is not one of the nine grounds referenced above may not be covered by that definition, but it is unacceptable. Examples of Inappropriate Behaviour are outlined in Appendix 2. 143 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

18.7.1 Sexual Harassment Sexual harassment is any form of unwanted verbal, non-verbal or physical conduct of a sexual nature that has the purpose or effect of violating a person's dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment for the person. This includes same-sex sexual harassment, and a single incident may constitute sexual harassment. Examples of conduct amounting to sexual harassment include but are not limited to: − physical conduct of a sexual nature such as unnecessary touching, patting, or pinching or brushing against another employee’s body, assault, and coercive sexual intercourse. − Verbal conduct of a sexual nature such as unwelcome sexual advances, propositions, or pressure for sexual activity, continued suggestions for social activity outside the workplace after it has been made clear that such proposals are unwelcome, unwanted, or offensive flirtations, suggestive remarks, innuendos, or lewd comments. − Non-verbal conduct of a sexual nature, such as displaying pornographic or sexually suggestive pictures, objects, written materials, emails, text messages, or faxes. It may also include leering, whistling, or making sexually suggestive gestures. − Gender-based conduct such as conduct that denigrates or ridicules or is intimidatory or physically abusive of an employee because of his or her sex, such as derogatory or degrading abuse or gender-related insults. Examples are outlined in Appendix 3. 18.8 RESPONSIBILITIES GCFS’s management and its employees have responsibility for creating and contributing to the maintenance of a work environment free from bullying and/or harassment. There is a responsibility on management to prevent bullying and/or harassment incidents, and act should any incidents be brought to their attention. Employees also have an obligation to cooperate with the investigation of complaints of bullying and/or harassment in the Company. Employees who make or participate in the investigation of a complaint will not be subject to victimisation of any kind for doing so. Nothing in this policy limits the right of GCFS to investigate any matter which may relate to bullying, harassment and/or sexual harassment in circumstances other than where a complaint has been made. All employees continue to have an obligation to cooperate with any such investigation. In particular, GCFS management will: − provide an excellent example by treating all in the workplace with courtesy and respect. − Promote awareness of the Company's policy and complaints procedures. − Be vigilant for signs of harassment and act before a problem escalates. − Respond sensitively to an employee who makes a complaint of harassment. − Explain the procedures to be followed if a complaint of bullying, sexual harassment or harassment is made. − Ensure that an alleged perpetrator is treated fairly. − Ensure that an employee making a complaint is victimised for doing so. 144 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

− Monitor and follow up the situation after a complaint is made so that bullying, harassment, or sexual harassment does not reoccur. 18.9 COMMUNICATION OF THE POLICY A hard copy of the policy will be provided to all employees as part of their induction. A soft copy is available from Joe Cashin. 18.9.1 Monitoring GCFS is committed to monitoring all incidents of bullying, harassment, and sexual harassment. The Company will compile and review all such relevant information at regular intervals and make any appropriate changes recommended from the reviews. 18.9.2 Training GCFS will provide appropriate training to managers, line supervisors and all employees to minimise the risk of bullying, harassment or sexual harassment occurring. 18.9.3 Designated Contact Person In the first instance all employees are asked to speak with their manager. If any employee has any question or query about the operation of this policy or requires any clarification about it, from their manager. Employees can approach their manager for advice, which will be given in the strictest confidence. In a situation where an employee is unable to speak with their manager, for what ever reason, then they can contact a Director of GCFS. Please note that speaking to the designated contact person is not the same as making a formal or informal complaint. 18.9.4 Complaints Procedure GCFS operates two methods of resolving complaints concerning bullying, harassment, or sexual harassment. Any such complaints will be handled with fairness, sensitivity, and due respect to both the complainant and the alleged perpetrator. 18.10 TIMEFRAME OF COMPLAINT In line with the Workplace Relations Commission’s Code of Practice, a complaint (informal or formal) must be made within six months of the latest incident of alleged behaviour. In order to enable GCFS to ensure a timely and effective outcome, a complaint should be made as soon as possible after a person has experienced bullying, harassment, or sexual harassment. 18.11 INFORMAL PROCEDURE Employees seeking to make a complaint under this policy must first contact the designated contact person and assess whether it is possible to resolve the problem informally in the first instance. The employee and the designated contact person will formulate the best approach, which will be one of the following: − the complainant explains clearly to the person engaging in the unwanted conduct that the behaviour is not welcome, or − the complainant, together with a friend, designated contact person or trade union representative, explains clearly to the person engaging in the unwanted conduct that the behaviour is not welcome. 145 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

In many cases, the informal approach will prove sufficient to allow the party whose behaviour is unwanted to recognise that their conduct is unacceptable. In those circumstances, certain complainants will be satisfied that this resolves the matter. 18.12 SELF – INITIATED. Any category as outlined under SCOPE who feels that they have been subjected to bullying, harassment or sexual harassment should approach the alleged perpetrator(s) and explain clearly that the behaviour in question is unacceptable and request that it stops immediately. If undertaking this approach, the individual should explain that the behaviour is not welcome, that it offends them and interferes with their work. Such an approach may enable the respondent to recognise their offending behaviour is a possible breach of GCFS’s Dignity at Work Policy & Charter and the impact this behaviour has had on the complainant and to cease that behaviour. See Appendix 4 for a guide to this process. 18.13 ASSISTED In circumstances where the staff member or contractor finds it difficult to personally raise the issue with the alleged perpetrator(s), they may wish to discuss the matter confidentially with a Contact Officer prior to proceeding with third party assistance to resolve the issue. A third-party person, for the purposes of informal resolution, cannot be the Contact Officer but may include a suitably trained and experienced mediator, supervisor, manager, HR, or staff member. These third-party people can assist in an informal approach with the alleged offender on a confidential and non-confrontational basis to discuss the matter with a view towards resolving the issue. The third-party, in this instance, could facilitate a resolution by getting the parties together. Consideration should be given to the needs of the complainant when determining how this process is to be conducted. Mediation is a voluntary, confidential process that allows two or more disputing parties to resolve their issues (conflict) in a mutually agreeable way with the help of a trained mediator. The objective of mediation, which is accessible without making a formal complaint, is to resolve matters speedily and confidentially without recourse to a formal investigation. It is intended that it will therefore involve the minimum of conflict and stress for the individuals involved. For more details, see GCFS’ Mediation Policy. 18.14 FORMAL PROCEDURE Formal complaints should be made to the complainant’s immediate manager or to a director of GCFS. The formal complaint should be in writing outlining precise details of the alleged incidents, e.g., specific allegations, details of behaviour, times, dates, and names of any witnesses. The formal procedure is appropriate where: − the complainant wants the complaint to be treated formally. − The alleged conduct is too serious to be treated under the informal procedure. − When the informal procedure has been unsuccessful. − The unwanted behaviour continues after the informal procedure has concluded. Formal complaints will be acknowledged within 5 working days. In progressing the complaint, GCFS may seek to ascertain whether a complete and confidential investigation is the only way forward or whether some other method might be recommended prior to initiating a full investigation of the complaint. 146 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

In order for the complaint to be addressed in a way other than the full investigation, GCFS will consult with both/all parties to the complaint. In all cases of a formal complaint, the respondent will be notified in writing that an allegation of bullying, harassment or sexual harassment has been made against them. If the matter proceeds to a formal investigation, a copy of the complainant’s statement, along with any other relevant information, will be issued to the respondent. The respondent will be advised that they will be afforded a fair opportunity to respond to the allegation(s), that GCFS has not formed any conclusion about the allegations and that the respondent has the benefit of the presumption of innocence pending the outcome of the investigation. 18.15 INVESTIGATION The objective of an investigation is to ascertain whether, on the balance of probabilities, the behaviours complained of occurred. Evidence and witness statements will be relied on for this purpose. Investigations into bullying, inappropriate behaviour, harassment, and sexual harassment will consider the impact of the behaviours on the complainant. GCFS will appoint a panel to conduct the investigation into the complaint. The investigation panel will be gender neutral and otherwise as diverse as possible with respect to the nine discriminatory grounds. GCFS is committed to investigating all complaints promptly, thoroughly, and objectively. The parties are assured that the investigation will be carried out with utmost confidentiality and sensitivity. The investigation will be conducted with due respect to the rights of both the complainant and the respondent in accordance with the principles of natural justice and fair procedures. The investigation will be based on the written complaint and any other matters relevant to the complaint. All witnesses or other parties required to conduct the investigation will be obliged to cooperate with the investigation panel’s directions. Parties to the complaint will be given copies of all relevant documentation at appropriate times (i.e., in advance of any meeting or interview at which the documentation will be discussed or relied on). During the investigation process, i.e., nature of the complaint, a written response from the respondent, meeting notes, minutes, etc., and signed witness statements (if any). The investigation will be governed by a precise term of reference based on the written complaint and any other matters relevant to the complaint. All parties and witnesses identified are obliged to cooperate fully with the investigation and on a confidential basis. The investigation will include separate interviews with the complainant, the respondent(s) and other staff or persons identified as witnesses to the alleged inappropriate behaviour. The investigation panel will conduct the investigation within the following terms of reference: − consideration of all relevant documentation submitted in connection with the complaint. − Cross-examination of the complainant, respondent, and witnesses. − All parties have the right to be accompanied during their interactions with the investigation panel by a colleague or trade union representative. − Written records of all meetings and investigations will be kept. 147 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

− Decide at this stage if it is appropriate to (a) carry out further investigations or (b) reach a conclusion. − During the process, all information gathered will be forwarded to the complainant and the respondent/s, and they will be entitled to respond before the investigation is concluded. − At the conclusion of the investigation, the investigation panel will produce a written report to both parties outlining its findings and the reasons for its final decision. − If the complaint is upheld, the investigation panel will recommend whether or not the Company's disciplinary process should be invoked. − If the complaint is upheld against a non-employee, the report will recommend appropriate sanctions. Where the complainant decides not to initiate a formal complaint, GCFS may investigate where allegations remain unsubstantiated. The same investigatory process will apply, and all parties will be obliged to fully cooperate. Employees must comply with the Equality Authority’s Code of Practice which states that a harassment complaint (whether formal or informal) must be made within six months of the most recent incidence of the alleged behaviour. 18.16 CONFIDENTIALITY Confidentiality will be maintained to the greatest extent possible throughout the investigation process, consistent with the requirements of a fair investigation. It is not possible to withhold the respondent's identity from the respondent because the respondent is entitled to know the full details of the complaint against them to be afforded an opportunity to defend themselves fully. Notwithstanding the difficult circumstances, both the complainant and the respondent may be expected to continue with their normal duties and maintain a professional working relationship during the course of any investigation. GCFS will, however, have due regard at all times for its obligations to safeguard the health, safety, and welfare of both parties and to any interaction, either party may have with the categories under SCOPE in this policy. A written record will be kept of all meetings, which will be treated in the strictest confidence. The complainant and respondent will be given the opportunity to comment on the minutes of relevant meetings held during the Formal Procedure within a set timeframe. They may wish to keep their own record. The investigators may interview anyone who they consider can assist with the investigation. All parties to an investigation are expected to cooperate fully with the investigation and will be fully supported throughout the process. Anyone who is required to participate in the investigation process will be obliged to respect the privacy of the parties involved and are not at liberty to discuss the matter with other work colleagues or persons outside GCFS other than their representatives. It will be considered a disciplinary offence to discuss any details, disclose information, refuse to cooperate, intimidate, or exert pressure on any person who might be required to attend as a witness (whether manager, colleagues, or other interested parties). 18.17 INVESTIGATION OUTCOMES At the completion of the investigation, a report determining whether an allegation of bullying, harassment, inappropriate behaviour, or sexual harassment has been substantiated or not will be prepared. This report will include: • The nature and details of the complaint. 148 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2

• The response of the respondent. • A determination as to whether any allegation of bullying, harassment, inappropriate behaviour, or sexual harassment has been substantiated or not or, alternatively, a determination as to whether the complaint was vexatious or malicious. • Recommendations for the next steps may include a recommendation the case be dealt with under the Disciplinary Procedure. The report will be forwarded to the Directors of GCFS, the complainant, the respondent, and, if applicable, their nominated and recognised colleague/union representative so as to be notified of the outcome of the investigation. 18.18 APPEALS If any of the parties to the investigation are dissatisfied with the outcome of the investigation, an appeal panel will be assembled to consider an appeal. The appeal panel will have had no prior involvement in the initial investigation, and if necessary external candidates will be appointed. The appeal will consider all the information considered by the investigation panel and conduct an interview with the appellant. 18.19 VEXATIOUS COMPLAINTS Any employees found to have made malicious or vexatious complaints will be subject to disciplinary action. Victimisation of complainants or witnesses to a complaint is deemed to be a serious disciplinary offence that will lead to disciplinary action up to and including dismissal. 18.20 PROTECTION AGAINST VICTIMISATION Victimisation or retaliation against a complainant, witnesses or any other party will constitute a serious disciplinary offence, which may include disciplinary action up to and including dismissal. 18.21 NON – EMPLOYEES GCFS will comply with EBS d.a.c Policies and Procedures. 18.22 POST INVESTIGATION Cases of bullying, harassment or sexual harassment may constitute gross misconduct resulting in termination of employment following the conclusion of a disciplinary process. Where no disciplinary action is recommended, the Company will explore whether counselling would be appropriate either for the person accused or the complainant. 18.23 REVIEW This policy will be reviewed annually. 149 | P a g e G C F S E m p l o y e e H a n d b o o k Ver 3 January 2 0 2 2