Following the entry into force of the Protected Disclosures Act 26 of 2000 (as amended) in South Africa, companies that meet certain requirements must implement an Internal Reporting System (hereinafter, “IRS”) or, where appropriate, adapt their existing Whistleblower Channel to that IRS, in accordance with the requirements set out in South African law.

In line with the foregoing, it should be noted that South African legislation allows the parent company or governing body of a corporate group to approve a general Policy in relation to its Whistleblower Channel, which must contemplate the principles of the Channel and the guarantees that must be complied with. Subsidiaries, with autonomy and independence, may make such modifications or adaptations as necessary to comply with the national regulations applicable in each case.

Therefore, following the culture of compliance that characterises The Alpha Student, the purpose of this Annex is to consider the main and essential characteristics established by South African regulations that must be applied by the Group’s South African subsidiaries to avoid legal infringement, without prejudice to the provisions of The Alpha Student’s General Policy.

As a tool for compliance with the above, The Alpha Student has set up the following Whistleblower Channel: whistleblower@thealphastudent.co.za, as a preferential channel for the submission of communications, or alternatively, by post to: The Alpha Student, Govan Mbeki,Gqebrha, Central, Eastern Cape South Africa – for the attention of the person responsible for the Whistleblower Channel.