Training and Awareness Policy

I. Purpose

The purpose of this policy is to establish guidelines for the development and implementation of training and awareness programs within Ondaro LLC and its affiliates (e.g., Ondaro do Brasil Consultoria Ltda., Ondaro Canada Consulting ULC, Cask Digital Services de Mexico, S. de R.L. de C.V. Mexico, among others), which hereinafter shall be collectively referred to in this policy as “Ondaro”. These programs aim to ensure that all employees, contractors, subcontractors, vendors and suppliers (“Third-Parties” or individually referred as “Third-Party”) understand and comply with the company’s policies, ethical standards, and applicable laws and regulations.

II. Policy Statement

Ondaro is committed to promoting a culture of integrity, ethical behavior, and compliance with all applicable laws and regulations. To achieve this, the company will provide regular training and awareness programs to ensure that all employees, contractors, and third-party service providers are knowledgeable about the company’s policies and their responsibilities.

III. Scope

This policy applies to all employees (including individuals engaged directly or through any employer of record), contractors, and third-party service providers of Ondaro. It covers all training and awareness activities related to compliance, ethics, anti-bribery, anti-corruption, data privacy, cybersecurity, and other topics identified as high-risk or legally required.

IV. Responsibilities

A. Senior Management

• Ensure the effective implementation and consistent enforcement of this policy across all levels of the organization.
• Provide support and resources.
• Demonstrate leadership commitment by actively participating in compliance initiatives.

B. Ethics and Compliance Officer

• Oversee, implement, and monitor training and awareness programs.
• Maintain accurate records of participation, in conjunction with the Human Resources Department.
• Conduct regular reviews and audits to ensure adherence to the policy and to identify opportunities for improvement.
• Align with Human Resources Department to address non-compliance and apply corrective actions.

C. People Team

• Conduct onboarding trainings to new collaborators.
• Conduct periodic trainings to all required stakeholders.
• Launch and document all required trainings.

D. Department Heads

• Ensure all team members complete mandatory training within required timeframes.
• Monitor participation and escalate non-compliance to the Ethics and Compliance Officer.
• Support the implementation of training and awareness initiatives.

E. Employees

• Complete all mandatory training and attest to understanding Ondaro policies.
• Apply knowledge gained in daily activities and decision-making.

V. Training Programs

A. Mandatory Training

• All employees, contractors, and third-party service providers must complete mandatory training programs on compliance, ethics, anti-bribery, anti-corruption, data privacy, cybersecurity, and other topics identified as high-risk or legally required.
• New hires must complete mandatory training as part of their onboarding process, within their first 30 days of employment.
• Failure to complete required training within the designated timeframes may result in disciplinary action in accordance with Ondaro’s Handbook applicable to the jurisdiction in which you carry out your duties.

B. Regular Training Updates

• Provide annual refresher courses and additional sessions when significant regulatory or policy changes occur.
• Update training content to reflect emerging risks and best practices.

C. Scenario-Based Learning

• Incorporate real-world scenarios, case studies, and interactive exercises into training programs to help employees understand how to apply ethical principles and company policies in practical, day-to-day situations.

D. Specialized Training

• Specialized training will be provided to employees and third-party service providers in high-risk roles or departments, including but not limited to Sales, Procurement, Finance, and Contract Management.
• Training content will be tailored to the specific responsibilities and risk exposure of each role, incorporating real-world scenarios.
• Participation in role-specific training must be completed within designated timeframes.

E. Tracking and Documentation

• Department Heads and the Ethics and Compliance Officer are responsible for monitoring completion rates and escalating non-compliance.
• The tracking process will enable Ondaro to:
  • Identify gaps in training coverage, particularly in high-risk areas.
  • Ensure timely compliance by employees, contractors, and third-party providers.
  • Continuously improve training programs by analyzing participation data, assessment results, and feedback to adjust delivery methods or content as needed.
• Effectiveness will be measured through completion rates, assessment scores, and reduction in compliance incidents.
• The Ethics and Compliance Officer will document and preserve all training records, per the Data Retention Policy and Data Retention Schedule of Ondaro.

VI. Awareness Initiatives

Ondaro, through its Senior Management and all level employees, will act according to the following principles:

Ethical Messaging

• Communicate the importance of integrity, ethical behavior, and compliance through newsletters, intranet posts, videos, emails, and/or quarterly leadership messages.
• Highlight examples of ethical behavior and recognize employees who demonstrate integrity.

Open Dialogue

• Encourage open dialogue about ethics and compliance.
• Facilitate regular forums, virtual town halls, and anonymous Q&A sessions to discuss ethical dilemmas and compliance challenges.
• Ensure participation from Senior Management and the Ethics and Compliance Officer to reinforce transparency.

Awareness Campaigns

• Launch ongoing campaigns using digital platforms and interactive content to promote the importance of compliance and ethical behaviors.

Leadership Commitment

• Ensure that Senior Management and executives consistently demonstrate ethical behavior and integrity in their actions and decisions. Leaders should also communicate their commitment to ethics during meetings, support compliance initiatives, and respond decisively to unethical conduct to reinforce trust and accountability. Their behavior sets the tone for the entire organization.

Effective Measurement

• Track engagement metrics (attendance, feedback, intranet views) and report quarterly to the Ethics and Compliance Officer.

VII. Effective Date

This policy is effective as of April 1st, 2026 and will remain in effect until amended or revoked by senior management.

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