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Whistleblowing Policy of IE Anglesey Food LLC.

1. Policy Goals and Objectives

The Company is committed to high standards of openness, honesty and accountability. We expect our employees and business partners who have concerns about the Company’s activity to refer us about the problems they exercise. 

Through the Company’s whistleblowing policy employees will have a chance to report inappropriate behavior or actions that violate this policy, other local regulations of the Company and/or Uzbekistan law. 

They are often the first to discover possible violations at the Company.  However, an employee may choose not to disclose his or her concerns, feeling that such statements would constitute a lack of loyalty in regard to co-workers or to the Company. They can also fear harassment. In such cases, it may be easier just to ignore the problem than to report it. 

The purpose of this policy is to encourage employees to report concerns without risk of harassment or discrimination. This policy allows employees to report problems within or about the Company that may be of serious concern to them, rather than ignoring the problem or seeking a solution outside the Company. 

2. Scope of Application.

This Policy is deemed mandatory for all employees of the Company, regardless of the level of their position, territorial location of the unit, type of employment contract, as well as all other persons who act on behalf of the Company. 

3. Definitions

Whistleblowing is an act of bringing potentially illegal and/or unethical practices, also known as committing violations, to the attention of management. 

The act of violation involves any illegal or unlawful conduct and may include, but is not limited to:
  • Failure to comply with any internal Company regulation
  • Deliberate violation of laws or regulations
  • Unprofessional conduct
  • Mistrustful accounting or auditing practices, fraud
  • Practices that could cause physical harm or damage to the person or property of the Company and associates
  • Failure to correct a problem that could cause significant expense or loss to the Company, or failure to take reasonable steps to report it
  • Abuse of right or authority for any unauthorized purpose
  • Harassment of any kind, infringement of rights, harassment by co-workers or management
  • Unfair discrimination, such as discrimination based on age, race, gender, religion, sexual orientation, marital status, having children, political views, or ethnic origin
  • Conflicts of interest.
This list is not complete; it only provides examples of actions that could be considered as the act of violation.

4.  Complaint/Notification of a Violation Process

If any violation is reported by any of its employees, consultants, contractors or suppliers, the Company will take immediate actions by thoroughly investigating and eliminating it. 

Contact Person: In the event of a complaint or concern, contact a line manager or business unit manager. The manager will decide whether to refer the matter to senior management, according to the seriousness and severity of the issues involved and the person suspected of having committed the violation. 

If the complaint concerns a person who is an immediate supervisor, or the employee wishes to file a complaint in another way, the notification should be sent in one of the following ways:
  • personal appearance at the Inspection Control Department,
  • personal appeal to the company’s in-house psychologist,
  • call the hotline at the phone number listed in KeepHub in the “Directory” section.
Letters and calls to the hotline are accepted from 09:00 to 18:00. Applications received on weekends and holidays, as well as after 18:00, will be registered on the date corresponding to the next working day. 

When contacting an employee of IE Anglesey Food, LLC, it is necessary to inform full name, position, shop/unit and their contact information for further contact with him/her. In the case of employee relatives contacting, the notice of violation/complaint will not be considered except when the employee cannot physically contact themselves. 

5. Process for Responding to a Notice of Violation/Complaint 

The Company will respond to any concerns that have been raised. However, the Company can only assess an issue after a preliminary review and, most likely, after conducting a proper investigation of the issue in question. 

The Compliance Department is responsible for reviewing and investigating employee complaints. Each notification is recorded in the appropriate log. 

In the case of gross violations, materials are referred to the ethics committee for review. Complaints and violations of all employees up to director level are handled within the framework of the current committee. Violations from director level upwards are referred to the Supervisory Board for review. 

In order to protect the individuals and suspects involved in the alleged violation, a preliminary review is conducted to decide whether an investigation is required and, if so, in what form it must be conducted. If urgent action is required, this will be done prior to the investigation. 

The investigation will include tools such as interviewing witnesses, cross-checking information from the employee who filed the complaint, and requesting additional information from appropriate employees.
Within ten business days after the issue is reported, the appropriate responsible employee will contact the person who filed the notice again and:
  • Acknowledges receipt of the report of the problem will;
  • Informs how the issue will be resolved;
  • Informs when a final response will be given;
  • Informs whether a preliminary review of the issue will be conducted; and
  • Informs if there will be further investigation and, if not, why not.
The Company will take steps to minimize the hardship the person filing the notice may encounter as a result of reporting the issue. The company recognizes that any person reporting concerns will require assurances that they have been acted upon. Subject to legal restrictions, the Company will provide information about the results of the investigation.

6. Timeframe

Problems will be investigated as soon as possible, to the extent reasonably practical, within 14 working days after the notice is received. It should be understood that it may be necessary to refer the matter to various persons, authorities, and that this may result in an extended investigation period. The seriousness and complexity of the complaint may also adversely affect the timeframe for investigating the matter. The Company will try to indicate the expected timeframe for investigating the complaint at the outset. 

7.  Protecting and preventing countercharges, harassment and bullying

Any employee who discloses or reports an issue under this policy will be afforded protection if the employee:
  • Discloses the information in good faith
  • Believes that it is substantially accurate
  • Does not act with malice or make false accusations
  • Does not seek any personal or financial gain.
The company will not permit any attempt by any person to sanction or discriminate against any person who has reported to the company a serious and genuine concern about an apparent violation. Any such harassment will be promptly dealt with and severe disciplinary consequences will ensue. 

8. Confidentiality and Anonymity 

The Company will maintain confidentiality with respect to any complaint received through the whistleblower notification process if the complainant requests confidentiality. It may be difficult to respond to and verify anonymous complaints if the complainant is not willing to reveal his or her name afterwards.

9. False and malicious allegations

The Company is committed to continuing to uphold the highest standards of honesty and integrity. The Company will ensure that sufficient resources are allocated to investigate any complaint it receives. However, it is important that any employee who plans to make allegations ensure that they are true.
The Company will consider the making of any knowingly false and malicious accusations by any employee of the Company to be a serious disciplinary offense that may result in disciplinary action, including termination of employment. 

10. Retention 

The original copy of this Policy shall be kept in the Human Resources Department.