Whistleblower Policy

Minterra FZC Trading Whistleblowing Policy

Purpose and scope

We are committed to creating and maintaining a culture of openness within our organisation so that individuals feel encouraged and confident to raise any concerns relating to suspected misconduct at an early stage. We also recognise the negative effect which malpractice can have on the organisation, and therefore encourage you to raise genuine concerns, or any suspicions you may have concerning misconduct. This Policy is non-contractual and may be amended by us at any time.

Protection

We appreciate that those reporting concerns may be apprehensive. We want to reassure you that you will suffer no detrimental treatment as a result of voicing your concerns. We will not tolerate victimisation, harassment, bullying or any other detrimental treatment of any worker who has made a disclosure under this Policy. Should you feel you have been subjected to any detriment as a result of raising a concern under this Policy you should notify operations manager.

Disclosures under this Policy

You can make a disclosure under this Policy if you have genuine concerns relating to any of the following areas of malpractice, or suspected malpractice:

• Criminal activity;
• Miscarriages of justice;
• Practices endangering health and safety;
• Practices damaging the environment;
• Failure to comply with a legal obligation;
• Failure to comply with companies Supply Chain Policy for a Responsible Global Supply Chain of Minerals from Conflict-Affected and High-Risk Areas;
• Bribery / Gift and Entertainment;
• Serious failure to comply with any ethical rules covering the business; and
• Attempts to conceal any of the above.

The malpractice can be past, present or prospective.

You are encouraged to report suspected wrongdoing as soon as possible. No action will be taken against you if you raise genuine concerns even if the concern you raised is not confirmed by any subsequent investigation.

Confidentiality and anonymity

Any disclosure you make under this Policy will be treated as far as reasonably practicable in a confidential and sensitive manner. If confidentiality is not reasonably practicable, for instance, because of the nature of the information, this will be explained to you.

We hope you will feel comfortable to voice any concerns openly, however, you may make a disclosure anonymously. However, concerns expressed anonymously cannot be dealt with as effectively as open disclosures as they are often more difficult to investigate.

How to make a disclosure

A disclosure or concern may be raised to Due Diligence Manager in writing via email to due.diligence@minterra.ae. If your disclosure contains allegations which you do not wish to make to Due Diligence Manager, you can make the disclosure to Director.

Investigation

Once a concern has been raised, we will investigate this. If you have not made the complaint anonymously, you will be asked to attend a meeting as part of this investigation.

We will keep you informed as to the progress of the investigation, as far as is possible and appropriate bearing in mind, in particular, any confidentiality obligations that apply. Please note that you will not be given details of any disciplinary action taken unless we consider this appropriate.

Training

All of our workers will receive an appropriate briefing to ensure that they are fully aware of their rights and responsibilities under this Policy.

All managers will be fully briefed as to their role in supporting this Policy and the appropriate action to take in the event of any disclosure being made to them.