Open door policy

An important aspect of accountability and transparency is a mechanism to enable staff and other members of the Company to voice concerns in a responsible and effective manner. It is a fundamental principle of every contract of employment that an employee will faithfully serve the Company and not disclose confidential information about the Company’s affairs to third parties without authorisation. Nevertheless, where an individual discovers information which they believe shows serious malpractice or impropriety within the organisation then this information should be disclosed without fear of reprisal, and there should be arrangements to enable this to be done independently of line management.

Examples of malpractice & impropriety include:

• Discrimination, harassment or abuse;
• Bribery, corruption or anti-competitive behaviour;
• Failure to comply with legal obligations;
• SHE (safety, health & environment) violations;
• Fraud, theft or other illegal activities;
• Inaccurate financial reporting.

Definitions may vary in certain jurisdictions according to legal restrictions that may apply.

The Open Door Line

Initially problems should be addressed to the line manager or Human Resources manager as they arise. If the individual believes that the matter has not been dealt with appropriately then the individual may make use of the Open Door Line (ODL), an outsourced confidential reporting facility (available in local language by telephone or email). The facility is set up to allow the individual to retain his/her anonymity, if the individual wishes to. Once a report is made through the ODL, the Company commits to:

• treating such disclosures sensitively and confidentially. The caller’s identity will not be revealed without the caller’s agreement;
• keeping the identity of the person suspected of wrong doing confidential whilst the investigation is underway;
• responding to the caller within 10 business days.

If an allegation is made in good faith but is not confirmed by the subsequent investigation, no action will be taken against that individual. However, if an individual makes an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against that individual.

All calls received by the outsourced service provider are forwarded to the Group Head of Risk who will then forward it to the appropriate individual(s) in the Company in line with the Open Door Policy.

All reports made through the ODL together with the outcome of the investigations are reported to the Audit Committee.