Whistleblowing Policy

Last Updated: December 16, 2025

Our commitment

Dream Finance Processing Inc is committed to integrity, transparency, and compliance with applicable Canadian regulatory standards, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), the Criminal Code of Canada, the Canada Labour Code, and all relevant provincial and federal governance, ethics, and workplace protection legislation.

If you observe behaviour that appears illegal, unethical, or improper, you can safely report it through our internal or anonymous channels.

We strictly prohibit any form of retaliation against individuals who report concerns in good faith. Every report is handled confidentially, professionally, and with respect for your rights.

What you can report

We encourage reporting concerns related to:

• Money laundering, terrorist financing, or sanctions violations
• Fraud, corruption, bribery, financial misconduct
• Violations of Canadian laws or regulations, including the PCMLTFA, Criminal Code, privacy legislation (PIPEDA), sanctions laws, securities laws (if applicable) and FINTRAC requirements
• Unethical, abusive, discriminatory, or inappropriate workplace behaviour
• Data protection or cybersecurity breaches
• Violations of internal policies or legal obligations
• Misconduct that harms clients, employees, partners, or the public

If you are unsure – report anyway. We review every submission.

Your protection

We are committed to creating a safe environment where concerns can be reported without fear of retaliation or exposure. If you report a concern in good faith, you are protected under applicable Canadian federal and provincial whistleblower protection laws, including but not limited to:

• the Canada Labour Code (anti-reprisal provisions)
• applicable provincial employment standards and occupational health and safety legislation
• the Criminal Code protections against intimidation and retaliation
• privacy protections under PIPEDA

When you report a concern:

• Your identity is kept confidential.
• You may report anonymously.
• Retaliation, threats, or negative treatment are strictly prohibited.
• Reports are reviewed fairly, objectively and without delay.

Review Process and Timelines

We ensure that every report is assessed fairly, impartially, and without delay.

1. Acknowledgement: We confirm receipt of your report within 3 business days.
2. Review timeline: Our goal is to complete the initial assessment and investigation within 30 days.
3. If more time is needed due to complexity, we will keep you informed.

How to report

You may report a concern through any of the following channels:

1. Anonymous online form (below on this page)
2. Email: [email protected]
   Handling based on topic:
   • For AML/financial crime: handled by the MLRO
   • For unethical behaviour: handled by HR

We ensure appropriate separation of duties and confidentiality throughout.

External Reporting

In cases where internal reporting is not possible or appropriate, or if the whistleblower prefers to report externally, the following competent authorities in Canada may be used:

In cases where internal reporting is not possible or appropriate, or if the reporter prefers to report externally, the following Canadian authorities may be used for submitting reports of illegal conduct, financial misconduct, whistleblower disclosures, etc.:

• Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)
  Address: 24th Floor, 234 Laurier Avenue West, Ottawa, Ontario K1P 1H7
  Website: https://www.fintrac-canafe.gc.ca
  Purpose: Reports related to money laundering, terrorist financing, sanctions violations, or breaches of MSB obligations.
  Issues concerning financial sector integrity, prudential matters, or related misconduct.
• Office of the Superintendent of Financial Institutions (OSFI)
  Address: 255 Albert Street, Ottawa, Ontario K1A 0H2
  Website: https://www.osfi-bsif.gc.ca
  In case of reporting fraud, scams, financial misconduct, corruption, or related behaviour.
• Canadian Anti-Fraud Centre (CAFC)
  Address: P.O. Box 686, North Bay, Ontario P1B 8J8
  Website: https://antifraudcentre-centreantifraude.ca
  In case of criminal offences, financial crimes, corruption, terrorism, cybercrime, and other illegal conduct.
• Royal Canadian Mounted Police (RCMP) – Federal Policing
  Address: RCMP Headquarters, 73 Leikin Drive, Ottawa, Ontario K1A 0R2
  Website: https://www.rcmp-grc.gc.ca
  In case of reporting breaches of privacy, misuse of personal data, or violations of privacy-related legislation.
• Office of the Privacy Commissioner of Canada (OPC)
  Address: 30 Victoria Street, Gatineau, Quebec K1A 1H3
  Website: https://www.priv.gc.ca

Other competent authorities and Legal protection under Estonian Whistleblower Law

• Other competent authorities and Legal protection under Canadian Whistleblower Laws
  Canadian federal whistleblower protections apply to individuals who report wrongdoing in good faith. These protections are grounded in legislation such as the Public Servants Disclosure Protection Act, the Criminal Code, the Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable Canadian laws.
• Under these laws, the identity of the whistleblower can be revealed only with the whistleblower’s written consent, and retaliation (dismissal, demotion, etc.) is prohibited.
• Whistleblowers are allowed to bypass internal channels and report directly to external authorities such as the Royal Canadian Mounted Police (RCMP), the Office of the Privacy Commissioner of Canada (OPC), the Canadian Anti-Fraud Centre (CAFC), the Office of the Superintendent of Financial Institutions (OSFI), and other competent Canadian authorities depending on the nature of the matter.