Whistleblowing Policy (Thailand)

1. Legal Landscape in Thailand

Thailand does not yet have comprehensive unified private-sector whistleblower protection legislation. Relevant protections are dispersed across multiple statutes:

• Organic Act on Counter Corruption B.E. 2561 (2018) (NACC Act): primarily protects whistleblowers reporting public-sector corruption.
• Witness Protection Act B.E. 2546 (2003, as amended): protects witnesses in criminal proceedings.
• Civil and Commercial Code: provides some protection against wrongful dismissal in limited circumstances.
• Labour Protection Act B.E. 2541 (1998, as amended): general labour rights protection.

2. Purpose of this Policy

In the absence of specific legislation, MiraNext GmbH establishes this internal whistleblowing policy as a matter of good governance, so that employees, partners and customers can report concerns safely.

3. Reportable Concerns

This policy covers reporting of the following concerns:

• Corruption, fraud or bribery.
• Violations of data protection law (PDPA) or privacy regulations.
• Breaches of medical device regulations or quality standards.
• Conflicts of interest.
• Unfair treatment or discrimination.
• Patient safety concerns related to MiraScribe.

4. Reporting Channels

Whistleblowers may report concerns through the following channels:

• Secure email: support@miranext.ai.
• Confidential online form: No separate online form is provided at this time; reports may be made by email to support@miranext.ai.
• Senior management (for issues involving a direct manager): the Managing Director of MiraNext GmbH, support@miranext.ai.
• External authority: National Anti-Corruption Commission (NACC): Office of the National Anti-Corruption Commission, 361 Nonthaburi Road, Tha Sai, Mueang, Nonthaburi 11000, Thailand. Hotline 1205. Online complaints at https://www.nacc.go.th.

5. Protections for Whistleblowers

MiraNext GmbH commits to:

• Maintaining the confidentiality of the whistleblower's identity to the extent permitted by law.
• Not retaliating against any person who makes a good-faith report.
• Investigating all concerns promptly and impartially.
• Informing the whistleblower of the outcome as appropriate.

6. False Reports

Intentionally false reports or reports made in bad faith may result in disciplinary or legal action.

7. Further Information

For questions about this policy, contact: support@miranext.ai.