whistleblowing
Policy

It is the policy of Starzs Investments Company Limited (SICL) to conduct its business fairly, honestly and with transparency. We expect all SICL directors, employees and anyone acting on our behalf to do the same and to maintain the highest standards of ethical business behavior. However, all organizations face the risk of things going wrong from time to time. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur.

As part of our core values and a key aspect of ensuring and maintaining SICL commitment to conducting business with such integrity and in an open and fair manner is providing a robust whistleblowing policy and reporting channel for SICL so that all colleagues,suppliers and third parties feel able to report any wrongdoing in confidence. At SICL, we encourage employees,suppliers and third parties to report any concerns as soon as they arise; such concerns can be of any nature.

The aim of this policy therefore is to:

• Encourage and empower colleagues,suppliers and third parties to speak up and report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.

• Provide colleagues,suppliers and third parties with guidance as to how to raise those concerns.

• Reassure colleagues,suppliers and third parties that they will be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

• Encourage a culture of openness.

This channel is open for staff to report matters which are considered under the human resources grievance procedure (for example harassment, bullying or discrimination) or are already the subject of a disciplinary procedure. All such employee relations group matters will be duly escalated to the Head of Human Resources for action.

However, this is not a policy to be used in order to question SICL financial decisions or business strategy.

Scope

This policy applies on a global basis to all SICL entities and personnel (including directors, executives, officers, employees, contractors, agency workers, casual workers, consultants and trainees) no matter which team they work in or which office. It relates to actions by such personnel as well as any concerns a colleague may have with one of SICL personnel, customers, suppliers or any other third parties with which SICL interacts or does business.

What type of misconduct should be reported?

As noted above, SICL wants to hear about such conduct that is unlawful, dishonest or unethical as soon as possible and is committed to addressing it.

The below provides examples of the types of misconduct or behavior that could give rise to a report; however, it is not an exhaustive list and SICL encourages all colleagues,suppliers and third parties to report any behavior or incidents which they have concerns about.

• Criminal activity or offenses, including fraud, theft, and embezzlement.

• Corruption, bribery or blackmail.

• Financial malpractice, impropriety or mismanagement.

• Conduct likely to damage SICL reputation or financial well-being.

• Actions which endanger the health and safety of SICL personnel or the public.

• Actions which cause damage to the environment.

• A miscarriage of justice.

• Unauthorized disclosure of confidential information.

• Employee harassment, bullying and discrimination.

• Any retaliation against someone for speaking up or “whistleblowing”.

• The deliberate concealment of information relating to any of the above matters.

Everyone has a responsibility to report any such misconduct or potential misconduct as soon as they become aware of it. If you are uncertain whether something is within scope of this policy, it is preferable that any concerns are reported rather than kept to oneself.

How to report a concern

SICL has put in place a dedicated, safe, secure and anonymous channel of escalation to members of staff of the Internal Audit department who are fully trained in whistleblowing reporting and procedures.

SICL has in place and will ensure that you are taken through and fully understand the overall process and next steps.

Google form – reporting channel Step 1. You will receive a monthly google form link from internal.audit@starzs-group.com

Step 2. Click on the link

Step 3. Form is set for you to report as an anonymous whistleblower.

Step 4. Leave a secure message

Step 5. Internal Audit receives email notification about report.

Step 6. Further dialogue with reporter if necessary.

This service is available twenty-four (24) hours a day and seven (7) days a week.

What will SICL do about concerns that are raised?

Once you have raised a concern, the Head Internal Audit will inform the MD/CEO, and a decision will be taken to investigate the matter.

However, the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. If we conclude that a whistleblower has made false allegations maliciously, the whistleblower will be subject to disciplinary action.

Protection against retaliation

SICL will ensure that genuine concerns raised of a reasonable belief can be raised without fear of retaliation and will not affect the continued employment, work or career with SICL of the person who raised their concerns.

SICL will not tolerate harassment, victimization or retaliation towards any person for raising concerns on the basis of a reasonable belief or objecting or refusing to participate in any act or practice that they honestly believe to be a misconduct in violation of SICL policies.

Any such harassment, victimization or retaliation will be treated as very serious and will be a disciplinary offence in accordance with SICL Human Resources disciplinary or SICL Supplier Code of Ethics and Business Conduct policy and procedures.

Confidential and anonymous reporting

All reports will be handled in complete confidence and the identity of the individual reporting the issue will be kept confidential.

As noted above, reports can be made anonymously using a google form link, in which case SICL will not find out the identity of the person who raised the concern.

An investigation stands a much greater chance of success if the person who raised the concern remains in communication via the google form link platform. Even if they choose to remain anonymous, it is still possible and desirable to establish a channel of communication.

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