Compliance Reporting

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 to support this behavior, and we have implemented internal controls and operating procedures to detect and prevent or deter improper activities; for employees, please see our Employee Guidebook for more details.

However, even the best internal systems of control cannot provide absolute safeguards against irregularities. We therefore encourage not just our employees, but also our advisors, investors, partners, vendors, and other parties to voice concerns in a responsible and effective manner when they discover information that they believe shows serious wrongdoing. In internal cases, a conversation between an employee and that person’s leader or a leadership team member will generally suffice, but this approach is not always feasible, and it is not available for non-employees to submit their concerns. We have therefore implemented an online compliance reporting process.

This process may only be used to report suspected violations of law or regulations, financial impropriety, 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 records, harassment, and inappropriate spending of cash through the accounts payable process. The process is not intended and may not be used to submit personal grievances, intercompany disputes, opinions on policy or strategy, shareholder matters, etc.

Since timely evidence increases the chance of a successful investigation, reports using this process should be submitted as soon as possible, preferably within three months of the occurrence of the event(s).

To file an online report, please fill in the fields on the company’s Compliance Reporting web page, check the confirm box, and click the “Submit” button. By filing a report, you acknowledge that an investigation may be initiated.

Alternatively, for a report involving a member of Orum’s leadership team or Audit Department, an email detailing the allegations and their factual basis can be sent to the following independent member of Orum’s Board of Directors: Jinwoo Jo.

Confidentiality

If you submit a report, we will maintain your confidentiality to the extent practicable within the limitations of the law, company policy, and the legitimate needs of the investigation. Only Orum’s Audit Department and Directors have access to submitted reports, and—as detailed below—any investigation would be handled by an outside investigator. However, if you submit a report that includes your personal information, you should be aware that an investigator may contact you and that your public testimony might be needed if investigation results in a court proceeding. In addition, if you 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.

Please note that, while your report of misconduct may possess merit, any comments you make to others regarding any employees who are the subject of your report could constitute defamation, invasion of privacy, or other grounds for civil liability. You should therefore not disclose 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

Orum’s Audit Department will maintain any compliance report it receives until the outcome of the investigation. No employee or member of Orum’s Board of Directors will actively participate in an investigation; the allegation will be referred to an external investigator. The investigator will have access to all resources of Orum and external counsel to ensure a fair and accurate resolution to the alleged violation.

The investigator is responsible for documenting its investigation and its rationale for the resolution. That document will be attached to any statements made in the course of compliance reporting and reside with the Human Resources Department following the investigation. The matter is closed when the Audit 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

If you provide personal information in your report, you will be informed of whether an investigation was warranted and, if so, the outcome. If the result of the investigation is that the allegations are not satisfactorily established, the investigation will be deemed complete. In this case, you will have the opportunity to communicate directly with the Human resource or Audit Department { hr, audit }@orurmx.com 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 Orum’s Board of Directors, 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, regulation, or company policy will have access to Orum’s grievance process described in the company’s Employee Guidebook.