Introduction

An important aspect of accountability and transparency is a mechanism to enable staff, and stakeholders of a company including the general public to voice genuine concerns in a responsible and appropriate manner.

Dhamana Guarantee Company Limited’s (the “Company”) values and facilitates the reporting of employees’ and other parties’ concerns about possible improprieties at the earliest opportunity to ensure that concerns/complaints can be raised without fear of reprisal or detrimental action.

The Company is committed to the highest standards of transparency, integrity, accountability and maintaining good corporate governance. The Company will not tolerate acts of victimization, reprisal or discrimination targeted against those who wish to raise concerns of malpractice or a complaint.

The Company takes concerns of malpractice seriously and encourages anyone who wishes to raise such concerns to do so confidentially and through the appropriate channels without fear of being victimized, discriminated against or disadvantaged.

Glossary

Policy Objectives

The objectives of this Policy are as follows:

a) To provide parties dealing with the Company with proper procedures in disclosing cases of Improper Conduct;

b) To manage disclosures of Improper Conduct in an appropriate and timely manner;

c) To provide protection to Whistleblowers from Detrimental Action that may result from the disclosure of Improper Conduct; and

d) To provide fair treatment to both the Whistleblower and the alleged wrongdoer.

Scope

This Policy applies to all Personnel, Service Providers and Recipients.

What issues can be raised?

For clarity, this Policy covers:

a) Complaints relating to any Improper Conduct.

b) Concerns about risk, malpractice or wrongdoing in relation to the Company’s activities which adversely affect the public interest, the Personnel or the Company itself. This includes actual or suspected misconduct, any actual or suspected breaches of the Company’s Code of Conduct, the Company’s Operating Policies and Procedures (including AML, health, safety, environment and social (“HSES”) policies, standards and procedures) or any actual or suspected breaches of applicable laws and regulations.

c) Unless it is in the public interest, this Policy does not cover personal complaints or disputes about their own position, circumstances or treatment raised by any Personnel. In such a case they should follow the internal grievance policy and procedures set out in the relevant staff handbook, their engagement letter or contract.

d) However, in cases where a Personnel genuinely considers the issue to be endemic/cause reputational damage within the Company or their department and no action has been taken in response to a concern raised as per grievance policy, then Whistleblowing may be appropriate.

The Whistleblower while making a report needs to have reasonable belief of the occurrence of Improper Conduct.

In order to give the Company an opportunity to investigate the alleged Improper Conduct and to take the necessary internal corrective actions, Whistleblowers are encouraged to lodge a report by providing, to the extent possible, the following information: -

• Description of the people or parties that are involved in the Improper Conduct;

• Details of the Improper Conduct, including the relevant dates of occurrence;

• Particulars of witnesses, if any; and,

• Particulars or production of documentary evidence, if any.

A disclosure of Improper Conduct may be made even though the person making the disclosure is not able to identify a particular person to which the disclosure relates.

For any concern any Personnel may have that may cause reputational damage or otherwise by association with any third party, they must still report the concerns even though they may not have all the required information. Failure to report serious concerns may be treated as a disciplinary matter.

Reporting

The Company’s vendors, contractors, consultants, and other third parties may report concerns first to the managers in charge of their contract.

Where the Whistleblower prefers to remain anonymous, then, they can report through the confidential reporting hotline as shall be established by the Company. When a disclosure is made orally, the person receiving the disclosure shall, as soon as practicable, deduce the same in writing.

If the Improper Conduct involves the Appointed Officer or any of the members of executive committees of the Board, the Whistleblower is to report the matter directly to the CEO. In case the matter involves a Board member the matter is to be reported to the chairperson of the Board or to any other Board member in case the matter involves the chairperson of the Board.

Any suspicious activity must be reported to the designated reporting channel i.e.,  transparency@dhamana.com

Protection of the Whistleblower

Upon making a disclosure in good faith, based on reasonable grounds and in accordance with and pursuant to this Policy:

a) The Whistleblower shall be protected from any Detrimental Action within the Company as a direct consequence of the disclosure; and

b) The Whistleblower’s identity and such other Confidential Information of the Whistleblower shall not be disclosed.

The protection against Detrimental Action is extended to any person related to or associated with the Whistleblower.

A Whistleblower may lodge a complaint to the Company of any Detrimental Action committed against the Whistleblower or any person related to or associated with the Whistleblower, by any employee of the Company.

The Whistleblower protection conferred under this Policy is not limited or affected notwithstanding that the disclosure of the Improper Conduct does not result in any disciplinary action of the person against whom the disclosure was made.

Administration of the Policy

The Legal & Compliance Manager (“LCM”) is the Appointed Officer and is responsible for the administration, interpretation, and application of this Policy.