Whistle-blower Protection Policy

Purpose

This Policy describes the  approach of Câm Dairy Foods Limited (the “Company”) to whistleblowing.

Applicability

This Policy is applicable to all Company operations, and all Representatives of the Company. It applies to any project where the Company has responsibility for the functions of the Responsible Official. Any deviation from this Policy requires the approval of the Responsible Official.

The Company has put in place Tools which support implementation of this Policy.

Definitions

“Business Partner” means any contractor, subcontractor, grantee, sub-grantee, awardee, sub-awardee, law firm, vendor, supplier, landlord, or other individual or organisation providing goods or services to the Company.

“Code of Conduct” outlines the minimum standards of conduct required by the Company. The Code of Conduct provides Employees and Representatives with a set of guiding ethical principles, associated obligations, and standards of conduct.

“Company” refers to Câm Dairy Foods Limited and all of its subsidiaries or related companies.

“Employee” means any person who has a part-time, full-time, intermittent, continuous, or fixed-term employment relationship with the Company.

“Good Faith” occurs when one makes a prudent effort to understand the facts without attempting to violate the confidentiality of others, considers the implication of those facts and any assumptions or opinions which   one believes are reasonable or probable, and acts openly without an ulterior motive to see that the matter is appropriately disclosed and resolved.

“Misconduct” means any behaviour or conduct (or attempt at such behaviour or conduct) that is prohibited by federal, state or local law, rule or regulation or the Company Code of Conduct, including bribery, sexual misconduct, human trafficking or forced labour, fraudulent billing or financial reporting, scientific misconduct, harassment, assault, and theft.

“Representative” means an Employee or any person who has an independent individual contractual relationship with the Company, whether as a contractor, consultant, or agent of the Company. This includes non-executive directors of the board.

“Tool” means templates, forms, charts, informational and any other material prescribed for use in conjunction with an element of a Policy.

“Whistle-blower” means a Representative or other individual associated with the Company who in Good Faith reports what they believe to be Misconduct by the Company or any individual or entity with which the Company has a business relationship.

Policy

The Company conducts its work with integrity, subject to the provisions of applicable regulation and ethical standards. The Company requires that  Representatives and other individuals, including third parties, associated with the Company who have reasonable grounds to suspect, or have actual knowledge of Misconduct, report such information to their line manager,  executive management or the Company’s compliance officer. Such reports may be disclosed through the compliance telephone hotline The Company conducts its work with integrity, subject to the provisions of applicable regulation and ethical standards. The Company requires that  Representatives and other individuals, including third parties, associated with the Company who have reasonable grounds to suspect, or have actual knowledge of Misconduct, report such information to their line manager,  executive management or the Company’s compliance officer. Such reports may be disclosed through the compliance telephone hotline +234 907 651 3173, or via emails to [email protected] .

Reporting of Misconduct

All persons are required to abide by the provisions of this policy. Any suspected or known violations of this Policy must be reported through the compliance telephone hotline +234 907 651 3173 or via an email to [email protected] .

Whistle-blower protection

The Company is committed to ethical behaviour and will not tolerate retaliation against a Whistle-blower. 

Any attempt to deter a Whistle-blower from reporting Misconduct is a serious offence and shall  be subject to  disciplinary action including termination of any contractual relationship with the Company.

The right of a Whistle-blower to protection against retaliation does not include immunity from investigations     of personal wrongdoing; disciplinary action for making a knowingly false, reckless, or otherwise bad faith allegation and legitimate measures taken to address any unrelated performance issues.

Whistle-blowers will not be disengaged, demoted, suspended, threatened, harassed, or discriminated against as a result of any lawful, good faith reporting of concerns.

Good Faith Allegation

While actual knowledge or proof of Misconduct is not required by this Policy, Whistle-blower’s allegations of Misconduct must be made in Good Faith and have articulable grounds.

A Whistle-blower is required to provide a full statement of the facts of which s/he is aware and of any assumptions or circumstances s/he believes are relevant to the allegation.

Once a Whistle-blower has made an allegation, the Whistle-blower is required to inform the Company of  any further relevant developments or changes in circumstance which informed the initial disclosure.

A Whistle-blower who knowingly makes a false, reckless, or otherwise bad faith allegation of Misconduct may  be subject to disciplinary actions, which may include the termination of any contractual relationship with the Company.

Anonymous allegations and confidentiality

Since appropriate follow-up questions and investigation may not be possible unless the source of the information is identified to Company management, Whistle-blowers are strongly encouraged to make  their report with attribution (non-anonymously).

Allegations made anonymously may not be considered in the same manner or with the same gravity as those made with attribution due to the inherent difficulty of substantiating facts where anonymous sources are concerned and the potential for abuse.

Duty to comply

It is the responsibility of each Representative of the Company to fully comply with this Policy. Failure to comply may be subject to disciplinary action including contract termination, contract non-renewal, or other  appropriate action.

Reporting

Representatives are required to report violations of this Policy to their manager or through the Company’s Whistle-blower mechanism.