Benchmark complaints policy

Purpose

The Benchmark Complaints Policy establishes a formal framework for stakeholders and employees to report concerns, whether internally or externally, regarding Modo Energy’s benchmark administration processes. The policy outlines clear procedures for handling complaints and reporting infringements to ensure regulatory compliance and foster stakeholder trust.

In particular, this process ensures that:

• Modo Energy makes available the complaints-handling policy through which complaints may be submitted on whether a specific benchmark determination is representative of market value, on a proposed change to the benchmark determination process, on an application of the methodology in relation to a specific benchmark determination, and on other decisions in relation to the benchmark determination process.

• Complaints are investigated in a timely and fair manner, with an initial response provided within 10 working days.

• The inquiry is conducted independently of any personnel who may be or may have been involved in the subject matter of the complaint.

• Individuals who make reports are guaranteed protection under Modo Energy’s Whistleblowing Policy, ensuring confidentiality and protection against retaliation.

Scope

This policy applies to all Modo Energy employees, directors, contractors, and consultants, as well as external stakeholders, including clients, partners, and regulatory bodies, and any third party with a legitimate interest in the benchmark process. It covers concerns related to benchmark determination processes and potential misrepresentations, suspected market abuse or regulatory non-compliance, conflicts of interest, misconduct or unethical behavior, and breaches of internal policies or applicable regulations.

Responsibilities

The following individuals and teams are responsible for ensuring the effective implementation and compliance with this policy:

• Chief Product Officer (CPO): Oversees the complaints and reporting process, ensuring transparency, compliance with regulatory requirements, and regular reporting to the Board of Directors and regulatory bodies as needed.

• Oversight Function: Independently reviews all complaints to ensure appropriate actions are taken in compliance with this policy and applicable regulations.

• Product Manager: Investigates complaints in cases where the CPO is involved, ensuring impartiality and transparency in the resolution process.

• Board of Directors: Reviews and escalates serious cases requiring corrective action and oversees the implementation of corrective measures and compliance with regulatory obligations.

Procedures

1. Logging Complaints

All complaints must be submitted via email to team@modoenergy.com or by using the Reporting Form available here. Complaints are reviewed by the Oversight Function and are logged in the Complaints Register for a minimum of five (5) years.

2. Complaint Investigation

• The CPO investigates all complaints, gathering evidence and reviewing relevant benchmark processes. Investigations are typically concluded in a timely and fair manner and the outcome of the investigation is communicated to the complainant within a reasonable period of time, unless such communication would be contrary to objectives of public policy or to applicable regulation.

• Where the CPO is, or may have been, involved in the subject-matter of the complaint, the matter will be investigated by the Product Manager to ensure impartiality.

3. Resolution and Reporting

Resolutions are documented and shared with the complainant (unless such communication would be contrary to objectives of public policy or to applicable regulation). If the issue requires further action, it is escalated to the Board of Directors for review.

4. Confidentiality and Protection

Modo Energy is committed to ensuring the confidentiality of all complaints and reports submitted under this policy. Whistleblowers are protected under the company’s Whistleblowing Policy, which provides safeguards against retaliation and ensures their anonymity if requested.

Violations & Enforcement

Failure to address complaints in accordance with this policy may result in regulatory penalties, reputational damage, and internal disciplinary actions.

Individuals found to have retaliated against whistleblowers will face immediate disciplinary measures.

Review Cycle

The Complaints Policy is reviewed annually to ensure it remains aligned with regulatory requirements and industry best practices.