Reportable misconduct covered under this policy includes but is not limited to: –

1. All forms of financial malpractices or impropriety such as fraud, corruption, bribery, forgery, blackmail, theft, misappropriation of funds and classified documents;
2. Failure to comply with legal obligations, statutes, and regulatory directives;
3. Actions detrimental to Health and Safety or the Environment;
4. Any form of criminal activity;
5. Improper conduct or unethical behavior that undermines universal and core ethical values such as integrity, respect, honesty, accountability and fairness etc.
6. Other forms of corporate governance breaches;
7. Connected transactions not disclosed or reported in line with regulations.
8. Insider abuse – where employees with special access privileges and knowledge of operations and information use this knowledge and information to alter or disable security controls for their own benefit and to the detriment of the Company
9. Non-disclosure of conflict of interest.

Once the disclosure is received, it will be assessed and where necessary, an investigation will be launched. A report on the findings will be presented and in consultation with the board, the appropriate action will be taken. Where the whistle blower wishes to know the feedback on the outcome of the investigation, a follow up is done to update them.

All concerns will be treated in confidence and every effort made not to reveal the whistleblower’s identity.

However, whilst making all reasonable effort to maintain the confidentiality of the matter as a whole, at a certain stage in the investigation it may be necessary to make the origin of the complaint known to the person or persons the allegations relate to.

This will be discussed with the whistleblower at the time.