Whistleblowing

Orum is committed to conducting its business in an ethical and legal manner and requires all of our employees to do the same. We have articulated and communicated a variety of policies (codified in this Guidebook) to support this behavior, and we have implemented internal controls and operating procedures to detect and prevent or deter improper activities. However, even the best systems of control cannot provide absolute safeguards against irregularities. We therefore encourage employees to internally voice concerns in a responsible and effective manner when they discover information that they believe shows serious wrongdoing. In most cases, this will take place in a conversation between the employee and that person’s leader or a Leadership Team member. However, at times an implemented this policy.

Whistleblowing is the important process of making claims of internal wrongdoing to a third party. You are probably aware of high-profile cases where whistleblowers report being besieged and isolated within their companies. However, Orum places a high value on the honesty and integrity of our team members, and we are therefore committed to ensure that whistleblowers benefit from a defined process and are protected from harassment or disciplinary proceedings.

We have provided mechanisms to assist and encourage employees to come forward in good faith with reports or concerns about suspected compliance issues and encourage timely reporting of suspected wrongdoing. However, we recognize there are times when an employee may feel it is necessary to report a concern of wrongdoing outside of the traditional reporting mechanism. Orum has adopted a whistleblower policy for these instances. This policy allows allegations to be made outside of the functional area with which the reporting employee is associated and allows for a degree of confidentiality for the employee, if requested.

We have provided mechanisms to assist and encourage employees to come forward in good faith with reports or concerns about suspected compliance issues and encourage timely reporting of suspected wrongdoing. However, we recognize there are times when an employee may feel it is necessary to report a concern of wrongdoing outside of the traditional reporting mechanism. Orum has adopted a whistleblower policy for these instances. This policy allows allegations to be made outside of the functional area with which the reporting employee is associated and allows for a degree of confidentiality for the employee, if requested.

This policy governs only the reporting and investigation of suspected violations of law, external regulations, a company policy of a financial nature, or the misuse of company resources. Such violations may include, but are not limited to, theft or inappropriate use of cash or other company property, bribery, falsification of hours worked for payroll purposes, and inappropriate spending of cash through the accounts payable process. The policy is not intended and may not be used for personal or employment grievances, general compensation and benefit issues, opinions on policy, etc.

To file a report under this policy regarding the actions of any employee other than the CEO or a member of the Human Resources Department can be made as follows:

• In Person: You may meet with the Human Resources Department and/or Auditing Department during its standard operating hours to file a report or request an appointment during non-standard operating hours.

• E-Mail: You may send to the Human Resources Department and/or Auditing Department a completed whistleblower disclosure statement (available from the Human Resources Department). You should understand that you may need to meet with the Human Resources and/or Auditing Departments to answer any questions from the review of the statement.

You should be aware that by filing a statement, you acknowledge your understanding that an investigation may be initiated.

For a report involving the CEO or a member of the Human Resources or Auditing Departments, an email detailing the allegations and their factual basis can be sent to the following independent member of the Board of Directors of Orum’s parent company: Jinwoo Jo.

Since it is often the case that timely evidence leads to the successful conclusion of such investigations, you should make a report under this policy as soon as possible, preferably within three months of the occurrence of the event(s) of concern. You may use other means outside of this policy to report a suspected problem after the three-month period.

Protection from Retaliation

If you report a suspected violation of law or company policy in good faith, you shall not suffer harassment, retaliation, or adverse employment consequences from other employees or Orum. We will discipline any employee who retaliates against someone who has reported a suspected violation in good faith, up to and including dismissal of the harassing employee. If you believe that you have been retaliated against after making a good faith report, you may report this alleged retaliation to the Human Resources and/or Auditing Department or the members of the Board of Directors to whom you originally made the report.

Confidentiality Under the Whistleblower Policy

If you initiate a whistleblower process, we will maintain your confidentiality to the extent practicable within the limitations of the law, company policy, and the legitimate needs of the investigation. In addition, if you submit a report, you should be aware that your public testimony might be needed if the whistleblowing investigation results in a court proceeding. In addition, if you self-disclose your identity directly or indirectly through your own actions outside of the official investigation process, Orum cannot, and is not obligated to, maintain your confidentiality.

Finally, while your report of misconduct may possess merit, you should be aware that any comments you make to others regarding any other employees who are the subject of your report could constitute defamation, invasion of privacy, or other grounds for civil liability. You should therefore not discuss your allegations outside of the reporting and investigation process. This is especially the case should the investigation prove that the suspected employee’s actions were lawful or within company policy.

Investigation Under the Whistleblower Policy

The Human Resources and/or Auditing Department will maintain any whistleblower disclosure statement it receives until the outcome of the investigation. Neither the Human Resources and/or Auditing Department nor any Director of Orum’s parent company will actively participate in an investigation but will refer the allegation to an appropriate investigator. The investigator/investigation team will have access to all resources of Orum and external counsel to ensure a fair and accurate resolution to the alleged violation.

The investigator/investigation team is responsible for documenting its investigation and its rationale for the resolution. That document will be attached to any original whistleblower disclosure statement and reside with the Human Resources Department following the investigation. The matter is closed when the Human Resources Department, Auditing Department, or Board of Directors, as applicable, has deemed the investigation to be complete and a resolution has been reached by the investigator/investigation team. Documents and evidence relating to any closed matter will remain in the Human Resources Department’s files.

Results When Reports Are Made Under the Whistleblower Policy

If the result of the investigation is that your allegation is not satisfactorily established, the investigation will be deemed complete. In this case, you will have the opportunity to communicate directly with the Human Resources and/or Auditing Department outside of this policy to further pursue your claim.

If the investigation establishes that a violation of law, external regulation, or company policy occurred, the Head of the applicable office of the investigated employee, or the Board of Directors of Orum’s parent company, as applicable, will determine appropriate action based upon law and company policy. Any individual who has been deemed to have committed an act in violation of law or company policy will have access to Orum’s grievance process described in this Guidebook.

Sanctions for a False Report

Reports made under this policy can have considerable impact on the personal and professional lives of those charged, both during the investigation and over the long term. We therefore need to make sure that employees do not intentionally misuse Orum’s Whistleblower Policy and procedures. Intentional misuse here includes, but is not limited to, frivolous claims; attempts to treat a personal grievance or personnel dispute as an allegation of wrongdoing; lack of good faith in invoking the policy; or any known false, malicious, or misleading statements made at any time under the procedures of the policy. If we determine after appropriate review that you have submitted a knowingly false report, we will take disciplinary action up to and including dismissal.