Whistleblower Policy

1. Purpose

Alstrum AI, Inc. ("Alstrum," "we," "us," or "our") is committed to maintaining the highest standards of ethics, integrity, and accountability. This Whistleblower Policy provides a mechanism for employees, contractors, partners, and other stakeholders to report concerns about illegal, unethical, or improper conduct without fear of retaliation.

2. What Can Be Reported

You may report concerns related to:

• • Financial Misconduct: Fraud, embezzlement, misappropriation of funds, or accounting irregularities
• • Security Violations: Data breaches, unauthorized access, or cybersecurity incidents
• • Regulatory Non-Compliance: Violations of SEC, FINRA, or other financial regulations
• • Ethics Violations: Conflicts of interest, bribery, or corruption
• • Workplace Misconduct: Harassment, discrimination, or unsafe working conditions
• • Privacy Violations: Mishandling of personal data or privacy breaches
• • Other Illegal Activity: Any conduct that violates laws or company policies

3. How to Report

Reports can be submitted through the following channels:

When making a report, please provide as much detail as possible, including dates, individuals involved, and any supporting documentation. You may choose to identify yourself or remain anonymous.

4. Non-Retaliation Policy

Alstrum strictly prohibits retaliation against anyone who reports a concern in good faith.

Any employee or contractor who retaliates against a whistleblower will be subject to disciplinary action, up to and including termination. If you believe you have experienced retaliation, please report it immediately using the contact information above.

5. Confidentiality

All reports will be handled with the utmost confidentiality to the extent permitted by law. Information will only be shared on a need-to-know basis for the purposes of investigating and addressing the reported concern. Anonymous reports are accepted and will be investigated to the extent possible.

6. Investigation Process

Upon receiving a report, Alstrum will:

• • Acknowledge receipt of the report (if contact information is provided)
• • Conduct a prompt and thorough investigation
• • Take appropriate corrective action based on findings
• • Communicate outcomes to the reporter where appropriate and legally permissible

7. Legal Protections

Whistleblowers may be protected under various federal and state laws, including the Sarbanes-Oxley Act, Dodd-Frank Act, and state whistleblower protection statutes. Nothing in this policy is intended to discourage or prevent you from reporting concerns to relevant regulatory authorities.