Whistleblowing

D&L Industries encourages the reporting of irregularities as described in the Company’s Policy on Fraud, Theft and Bribery, and will protect the identity of whistle-blowers and persons cooperating in the investigation of irregularities. Reported irregularities will be investigated and appropriate actions will be taken.

WHISTLE-BLOWER PROTECTION

An employee who complains of retaliation, reprisal or harassment with respect to a whistle- blower activity should file a report with the Director, Human Resources, who will conduct a review of the complaint to determine whether the act in question constitutes retaliation, reprisal or harassment and performs appropriate resolution. The Group assures that those reporting do not suffer the consequence of disclosing in confidence what they know.

PROCEDURES

In reporting irregularities, a whistle- blower can choose to notify the Manager of Internal Audit, the designated Director of the Company, or the Audit Committee via mail, email, and telephone. Reports by mail and email must include a filled out Whistleblowing form marked CONFIDENTIAL.  

INVESTIGATION AND RESOLUTION

Where irregularities are reported to the designated Director of the Company, the Director informs the Chairman of the Board and, in consultation with the President and Chairman, determines a course of action.

All whistle-blower reports received by the designated Director are forwarded to the Manager of Internal Audit for processing.

The Manager of Internal Audit maintains a confidential record of whistle-blower reports and notifies the Chairman of the Board and President of received reports.

The Manager of Internal Audit prepares the plan, scope and schedule of the investigation. The whistle-blower should be informed that report has been received, an investigation will be conducted, and the whistle-blower may be contacted for further information as the investigation proceeds.

If, during the course of an investigation, the facts appear to be indicative of an illegal act, the Manager of Internal Audit should advise the President and the Chairman; recommends if further investigation should be turned over to relevant authorities; and seeks specialized assistance if required to complete the investigation

On completion of the investigation, a summary of the investigation steps, facts found and conclusions are documented in a confidential investigation report by the Manager, Internal Audit.

REPORTING

The Manager of Internal Audit maintains a file of completed investigation reports.

The Manager of Internal Audit reports to the Chairman of the Board, the President and the Audit Committee on the status of investigations concerning reported irregularities every month.

During the course of or after concluding the investigation, depending on the individual circumstances, the Manager of Internal Audit should contact the whistle-blower (except in cases where the whistle-blower has requested not to be contacted) to provide information concerning the progress and / or outcome of the investigation to the extent that such disclosures does not compromise a person’s rights, privacy or confidentiality.

 

CONFIDENTIALITY

All information in relation to this Policy are considered confidential. Personal information will not be disclosed to any unrelated party unless it is for purposes of conducting the investigation, reporting to the authorities, or taking disciplinary or legal action. Any employee who makes a report or is interviewed during an investigation must keep all information confidential.