17. Whistleblower Policy

INTRODUCTION

Aluminij Industries (hereinafter “Aluminij” or “we”) is committed to high standards of transparency, accountability, ethics and integrity, creating a culture where everyone feels free to speak about concerns securely and confidentially.

We are also committed to ensuring concerns are treated seriously and handled and/or investigated in a manner that protects a whistleblower’s identity.

We do not tolerate retaliation against anyone who speaks openly about conduct they believe is unethical, illegal or not in line with our Code of Business Ethics and policies, even if the concern doesn’t turn out to be substantiated, and as long as it is not raised knowing it is false.

PURPOSE

This policy is intended to inform all current and former employees and others (consultants, customers, suppliers and other third parties) of this commitment, to encourage reporting of possible violations at the earliest opportunity, and to lay out procedures for reporting and investigating complaints and the protections afforded to whistleblowers.

DEFINITION

A whistleblower is a person reporting information that he/she suspects on reasonable grounds to be about or to indicate a protected concern. A whistleblower may or may not be directly affected by a protected concern.

SCOPE OF THE POLICY

A whistleblowing concern covered under this policy include:

  • All forms of financial malpractices or impropriety such as fraud, corruption, bribery, theft and concealment;
  • Failure to comply with legal obligations, statutes, and regulatory directives;
  • Actions detrimental to Health and Safety or the work environment;
  • Any form of criminal activity;
  • Improper conduct or unethical behavior that undermines universal and core ethical values such as integrity, respect, honesty, accountability and fairness;
  • Other forms of corporate governance breaches;
  • Connected transactions not disclosed or reported in line with regulations;
  • Insider abuse;
  • Non-disclosure of interests;
  • Workplace or sexual harassment;
  • Attempt to conceal any of the above listed acts.

Although the whistleblower is not expected to prove the truth of an allegation reflected in the reported concern, if the whistleblower has evidence to demonstrate that there are sufficient grounds for concern and enough to warrant further investigation, the whistleblower is expected to produce such evidence.

This policy does not supersede the terms of any collective bargaining agreement or any other applicable law.

CONFIDENTIALITY AND ANONYMITY

A whistleblowing concern can either be made confidentially or anonymously:

  • Full Disclosure – the whistleblower’s name is known and will be disclosed in the report
  • Partially Anonymous – the whistleblower's name is known but will not be disclosed, without their consent, unless required by law.
  • Anonymous whistleblowing – the whistleblower does not identify themselves to anyone at any stage.

Whistleblowers may submit protected concerns anonymously without disclosing their identity. However, proper handling and/or investigation is more difficult, and sometimes impossible, if Aluminij does not know the whistleblower’s identity.

Generally, whistleblower is encouraged to provide his/her name because it will make it easier for Aluminij to assess, investigate and address his/herdisclosure. If whistleblower do not provide his/her name, the investigation will be conducted as best as possible in the circumstances and whistleblower will still be protected in accordance with this Policy. Sometimes an investigation may not be possible unless enough information is provided, and it may make it difficult to offer whistleblower the same level of practical support if we do not know his/her identity.

POLICY BREACHES

This Policy support our values and reflect what is important to Aluminij. Non-compliance with this Policy may result in disciplinary action.

Depending on the severity of the breach, consequences may range from a warning to termination of employment.

POLICY REVIEW

This Policy shall be reviewed periodically.

Aluminij reserves the right to modify this policy, in whole or in part, at any time. Aluminij may also establish further rules and procedures, from time to time, to give effect to the intent of this policy and further the objective of good corporate governance.

 

 

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