This Whistleblowing Policy (the “Policy”) applies to Feronia Inc. and each of its subsidiaries (collectively, the “Corporation” or “Company”) in the Democratic Republic of the Congo.
Whistleblowing occurs when the employee knows or suspects that there is some wrongdoing occurring within the organisation and alerts the employer accordingly.
Making a Report
If an employee knows, or suspects, that some wrongdoing is occurring within the Corporation, he or she should raise the matter immediately with their line manager. If the employee is not able to approach their line manager, for example if it is believed that they are involved in any wrongdoing, the employee should contact their local Compliance Officer or state their concerns in writing to email@example.com
Although this list is not exhaustive, examples of situations in which it might be appropriate for an employee to report a wrongdoing include:
A breach of the Corporation’s Anti-Bribery Policy.A Breach of the Feronia Code of Business Conduct.A breach, or potential breach of health and safety policy or legislation. Financial irregularities.Harassment of a colleague, customer or other individual.Damage to the environment. The committing of a criminal offence.
Action by the Corporation
Any manager or representative of the Corporation who is informed by an employee of a potential wrongdoing should advise their Compliance Officer.
The Compliance Officer will take immediate action on behalf of the Corporation to investigate the situation.
The employee who has raised the issue of wrongdoing will be kept informed of any investigation that is taking place. The employee will also be informed of the outcome of the investigation. It might not be always appropriate to tell the employee the exact detail of any action that is taken, but the employee will be informed that action is taking place.
Alerting Outside Bodies to a Potential Wrongdoing
An employee should always, in the first instance, talk to a manager in the Corporation or the Compliance Officer about a potential wrongdoing. If the employee is not satisfied with the response, he or she may contact a relevant external body to express their concerns.
In doing this the employee should:
Have a reasonable belief that the allegation is based on correct facts. Not be making any personal gain from the allegation. Make the disclosure to a relevant and appropriate external body.
Contacting the Media
The media is not a relevant external body. Employees should not contact the media with allegations about the Company.
Protection against Detriment
The Corporation will take reasonable steps to protect an employee in relation to any allegations which are made.
Employees should however follow the procedure set out in this policy, where the procedure is not followed, protection against detriment will not apply.
Making allegations or disclosing information in an inappropriate way (e.g. contacting the media or malicious allegations) could result in disciplinary action being taken against the employee.
The Corporation will communicate proactively with management and employees to ensure they are aware of their responsibilities under this policy and are empowered to apply it through the necessary education, training and support.
Review and Reporting
The Group Compliance Officer will monitor and review and at least annually report to the Feronia Board of Directors on
i) the effectiveness of this Policy,
ii) the adherence by Corporation employees to this Policy,
iii) the steps taken by the Corporation to implement the Policy.
Group/UK Compliance Officer: Bhushan Pattanaik, Group Financial Controller
DRC Compliance Officer: Evariste Lubaki, Head of DRC Personnel