Whistleblower Policy

Commitment to Integrity

REBELO SECURITY INTERNATIONAL, Inc. (“RSI,” “we,” “our,” or “the Company”) is committed to conducting business with the highest standards of honesty, integrity, professionalism, accountability, and legal compliance. We encourage all employees, contractors, clients, vendors, and other stakeholders to report concerns regarding suspected misconduct without fear of retaliation.

This Whistleblower Policy establishes procedures for reporting suspected violations of law, unethical conduct, fraud, safety concerns, or violations of Company policies.

Purpose

The purpose of this Policy is to:

  • Promote ethical and lawful business practices.

  • Encourage the timely reporting of suspected wrongdoing.

  • Protect individuals who report concerns in good faith.

  • Ensure reports are investigated fairly, objectively, and confidentially.

  • Prevent retaliation against whistleblowers.

Scope

This Policy applies to:

  • Employees

  • Independent Contractors

  • Security Officers

  • Executive Management

  • Directors and Officers

  • Consultants

  • Temporary Personnel

  • Vendors and Suppliers

  • Clients

  • Business Partners

  • Applicants

  • Any individual interacting with REBELO SECURITY INTERNATIONAL, Inc.

Reportable Concerns

Individuals are encouraged to report any activity they reasonably believe constitutes misconduct, including but not limited to:

Fraud and Financial Misconduct

  • Theft

  • Embezzlement

  • Fraudulent billing

  • Payroll fraud

  • Expense reimbursement fraud

  • Misappropriation of Company assets

  • Accounting irregularities

  • False financial reporting

Legal and Regulatory Violations

  • Violations of federal, state, or local laws

  • Licensing violations

  • Regulatory non-compliance

  • Falsification of records

  • Contract violations

Ethical Misconduct

  • Conflicts of interest

  • Bribery or corruption

  • Acceptance of improper gifts

  • Abuse of authority

  • Dishonest business practices

  • Misrepresentation to clients

Workplace Misconduct

  • Harassment

  • Discrimination

  • Retaliation

  • Workplace violence

  • Bullying

  • Intimidation

Security and Safety Concerns

  • Unsafe work practices

  • Negligence affecting client safety

  • Improper use of force

  • Failure to follow security procedures

  • Breaches of confidential information

  • Data security violations

  • Physical security vulnerabilities

Other Concerns

  • Violations of Company policies

  • Misuse of Company property

  • Substance abuse affecting job performance

  • Environmental violations

  • Any conduct that could damage the Company’s reputation or operations

Good Faith Reporting

Reports should be made honestly and in good faith. A good faith report means the reporting individual reasonably believes the information provided is true, regardless of whether an investigation ultimately substantiates the concern.

Knowingly making false or malicious allegations may result in disciplinary action, contract termination, or other appropriate legal remedies.

Confidentiality

RSI will make reasonable efforts to protect the identity of individuals reporting concerns.

Information will only be disclosed when necessary to:

  • Conduct an effective investigation;

  • Comply with legal obligations;

  • Protect individuals or Company assets; or

  • Cooperate with law enforcement or regulatory agencies.

Absolute confidentiality cannot be guaranteed in every circumstance.

Anonymous Reports

Anonymous reports are accepted.

However, providing contact information may assist investigators in obtaining additional information necessary for a thorough review.

Reporting Procedures

Concerns may be reported through any of the following channels:

  • Immediate Supervisor (when appropriate)

  • Operations Management

  • Human Resources

  • Corporate Compliance

  • Executive Management

  • Company-designated reporting email

  • Company reporting hotline (if available)

Reports should include, whenever possible:

  • Description of the concern

  • Date(s) and time(s)

  • Individuals involved

  • Witnesses

  • Supporting documentation

  • Any other relevant information

Investigation Process

All reports will be reviewed promptly.

Depending upon the nature of the allegation, the Company may:

  • Conduct an internal investigation

  • Interview relevant individuals

  • Review documents and evidence

  • Consult outside legal counsel

  • Engage independent investigators

  • Notify law enforcement or regulatory agencies when appropriate

Investigations will be conducted fairly, objectively, and impartially.

Non-Retaliation

REBELO SECURITY INTERNATIONAL, Inc. strictly prohibits retaliation against any individual who, in good faith:

  • Reports suspected misconduct;

  • Participates in an investigation;

  • Cooperates with investigators; or

  • Refuses to participate in unlawful activity.

Retaliation includes, but is not limited to:

  • Termination

  • Demotion

  • Harassment

  • Intimidation

  • Reduction in hours

  • Loss of assignments

  • Threats

  • Discrimination

  • Adverse employment actions

Anyone engaging in retaliation may be subject to disciplinary action, up to and including termination of employment or contractual relationship.

Cooperation Requirement

Employees and contractors are expected to cooperate fully with investigations conducted under this Policy.

Failure to cooperate or intentionally interfering with an investigation may result in disciplinary action.

False Reports

This Policy protects individuals making reports in good faith.

However, intentionally false, misleading, or malicious reports are prohibited and may result in disciplinary action, contract termination, or legal action.

Record Retention

Reports and investigation records will be maintained in accordance with applicable laws, Company record retention policies, and confidentiality requirements.

Compliance with Applicable Laws

This Policy is intended to comply with applicable federal, state, and local whistleblower protection laws.

Nothing in this Policy is intended to discourage or prevent any individual from reporting possible violations of law to appropriate governmental or regulatory agencies or from exercising any rights protected under applicable law.

Questions

Questions regarding this Policy may be directed to the Company’s Corporate Compliance or Human Resources Department.

Policy Review

REBELO SECURITY INTERNATIONAL, Inc. reserves the right to amend, revise, suspend, or update this Policy at any time to ensure continued compliance with applicable laws and best business practices.

Our Commitment

Integrity is the foundation of our organization. Every employee, contractor, client, and business partner shares responsibility for maintaining a workplace built on honesty, accountability, professionalism, and respect.

We encourage anyone with legitimate concerns to speak up so that issues can be addressed promptly, fairly, and responsibly.

Last Updated: July 9, 2026