Whistle Blowing Policy

1.1. Purpose

Any person (whistle blower) with well-intention raising a secret or anonymous concern regarding a potential wrongful behavior. Whistle blowers are not those who report through ordinary administrative channels for the public.

This policy ensures to protect all members of the Board and its committees, executives, and employees (concerned persons) who work for SADAFCO and reported, with good faith, any suspected violations by any Board member or concerned person.

This policy aims to facilitating reporting procedures and encouraging concerned persons to reveal any wrongdoings or bad behaviors immediately. This policy will also ensure protection for concerned persons from any victimization or detriment upon making a disclosure.

1.2. Introduction

This policy encourages all employees to report potential violations in preparing financial reports, or any wrongdoings as soon as possible, in an appropriate manner.

This policy was developed for the following purposes:

  • To support our values; respect for all, integrity, quality, and passion.
  • To respect human rights and humanity, and no discrimination acts shall be performed against employees or acts violating human rights based on race, nationality, religion, beliefs, gender, or any other reason.
  • To cultivate a proper environment to help employees perform their duties effectively. Relations between the Board and other employees shall be based on mutual respect and teamwork, bearing in mind that any offense such as harassment and abusing authority of position is an affront to the dignity of human and will not be tolerated at workplace.
  • To treat colleagues fairly and respectfully, and help them to develop, improve, work with the team and strive for change.
  • To take a resolute stance against any criminal groups or anti-social practices.
  • To ensure employees can raise any matters of genuine concerns without fear of reprisals.
  • To establish a clear and transparent mechanism to deal with doubts and concerns.

This policy does not only include improper practices in matters of financial reporting, but also includes the following:

  • Corruption, bribery, and blackmailing.
  • Criminal offences.
  • Non-compliance with legal and regulatory commitments
  • Jeopardize the safety of individuals.
  • Unauthorized use of Company’s funds.
  • Other unethical conduct.
  • Concealing the abovementioned practices.

1.3. Principles

  • All raised concerns will be treated fairly and clearly.
  • The Company will not tolerate harassment of any kind to harm the reporter.
  • Any person who raised a concern reserves the right to keep his/her identity as secret, unless agreed otherwise.
  • The Company assures that the whistle blower will know who will handle his concerns.
  • The Company will ensure protection for such persons from any victimization or detriment as a result of having made a disclosure, even if the disclosure was false but was made with good faith. However, other disclosures made maliciously, in bad faith, will be excluded from such protection.

1.4. Reporting Mechanism

Any employee, reasonably and with well-intention believes that there are malpractices occurring at the workplace shall report to his/her line supervisor immediately. If this employee hesitated to bring this information to his/her supervisor, he/she shall report to Human Resources Director.

The employee can be confidant to speak to an independent third party to raise his/her concerns on the Hotline. These concerns will be reported to the Company without revealing the identity.

This appointed party will receive reports through appropriate channels and investigation resources to deal with complains, when necessity arises, it will route this concern to the Audit Committee to reach a decision.

Reporting employees (whistle blowers) will be informed of the progress of the investigation, and how to communicate the investigator. The Company will provide remarks and opinions as practicable, without jeopardizing the privacy of others.

The Company will not disclose the identity of the employee who reported his/her concerns. However, the whistle-blower’s identity could still become apparent to third parties (as an evident to the court) during the course of an investigation. The Company will take proper actions regarding informing the employee.

If the whistle blower has followed all the necessary procedures and he/ she still has some concerns that cannot be discussed with abovementioned parties, he/ she may refer their concerns and complaints to the dedicated complaints handling team.

1.5. Inaccurate Reporting

The malicious use of this Code may lead to disciplinary actions against the complainant, up to and including termination of employment.

1.6. Review and Amendments

The effectiveness and efficiency of this Code shall be assessed periodically. The Company may review and amend the terms of this Code from time to time in conformity with the amendments of related practices and laws.

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