1. Purpose and Scope

This Whistleblowing Policy (the “Policy”) provides a framework for employees, contractors, and third parties to report concerns about illegal, unethical, or improper conduct within the company. The Policy ensures that such reports can be made without fear of retaliation and that concerns are appropriately investigated and addressed.

2. Policy Statement

The company is committed to maintaining a culture of openness, accountability, and integrity. Employees and associated persons are encouraged to report any concerns about misconduct. The company will investigate all reported concerns thoroughly and fairly, maintaining confidentiality to the extent possible.

3. Definitions

• Whistleblowing: Reporting by an employee or third party of suspected wrongdoing or dangers at work.
• Misconduct: Includes but is not limited to fraud, bribery, corruption, financial irregularities, harassment, discrimination, and any violation of laws or company policies.
• Retaliation: Any adverse action taken against someone for reporting misconduct, such as dismissal, demotion, harassment, or any other form of discrimination.

4. Reporting Procedures

• Who Can Report: Any employee, contractor, or third party who has a genuine concern about misconduct.
• What to Report: Any suspicion or evidence of illegal, unethical, or improper conduct.
• How to Report: Concerns can be reported through multiple channels:
  • Directly to a manager or supervisor.
  • To the Compliance Officer via email, phone, or in person.

5. Confidentiality and Anonymity

• The company will make every effort to protect the identity of the whistleblower.
• Reports can be made anonymously, but providing contact information may assist in a more thorough investigation.
• Information disclosed during the investigation will be kept confidential, except where disclosure is necessary for a thorough investigation or required by law.

6. Investigation Process

• Upon receiving a report, the Compliance Officer will acknowledge receipt and conduct a preliminary assessment.
• A full investigation will be conducted if the preliminary assessment indicates sufficient grounds.
• The investigation may involve interviews, document reviews, and collaboration with internal or external experts.
• The whistleblower will be informed of the outcome, subject to legal and confidentiality constraints.

7. Protection Against Retaliation

• The company strictly prohibits retaliation against anyone who reports misconduct in good faith.
• Any employee found to be retaliating against a whistleblower will face disciplinary action, up to and including termination of employment.
• Whistleblowers who believe they have faced retaliation should report this to the Compliance Officer or use the whistleblowing hotline.

8. False Reports

• While the company encourages the reporting of genuine concerns, it also expects that reports are made honestly.
• Deliberately making a false report for malicious purposes will result in disciplinary action.

9. Training and Communication

• Regular training will be provided to employees on the whistleblowing process and the importance of reporting misconduct.
• The Policy will be communicated to all employees, contractors, and relevant third parties.

10. Monitoring and Review

• The Compliance Officer will monitor the implementation and effectiveness of this Policy.
• The Policy will be reviewed annually to ensure it remains effective and compliant with legal requirements.

11. Contact Information

For questions or concerns about this Policy or to report misconduct, contact the Compliance Officer at [email protected]/01229483850

Appendix: Example Scenarios

Scenario 1: Financial Misconduct

Situation: An employee notices discrepancies in the financial records indicating potential embezzlement. Action: The employee reports the concern through the confidential whistleblowing hotline.

Scenario 2: Workplace Harassment

Situation: An employee experiences harassment from a supervisor but fears retaliation if they report it. Action: The employee uses the anonymous online reporting system to report the harassment.

Scenario 3: Environmental Violations

Situation: A contractor observes improper disposal of hazardous waste by the company. Action: The contractor contacts the Compliance Officer to report the violation.

By adhering to this Policy, we ensure that concerns about misconduct are addressed promptly and appropriately, fostering a safe and ethical workplace environment.