OBJECTIVE

The objective of this policy is to provide a platform and mechanism for directors, employees and suppliers to properly address bona fide concerns within the organization without fear of reprisal.

It encourages directors, employees and suppliers about their duty to report any suspected activity that violates any law applicable to the Company, its Core Values or Code of Conduct.

This policy is intended to assist only those individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the organization nor should it be used to reconsider any matters which have been investigated under the harassment, grievance or disciplinary policies and procedures.

POLICY STATEMENT

Mirpurkhas Sugar Mills Limited (MSM) is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, Mirpurkhas Sugar Mills Limited has developed a Whistle Blowing Policy to lodge complaint or to bring in the knowledge of the competent authority any unfair treatment, fraudulent, immoral, unethical or malicious activities or discrimination or some other type of adverse occurrence that violates a law, regulation, policy, morals and/or ethics and especially those matters that jeopardize the credibility and reputation of the company. The whistle can be blown by any director, employee or supplier without fear of punishment/unfair treatment.

SCOPE/APPLICABILITY

This policy is applicable to directors, all permanent and third party employees and suppliers of Mirpurkhas Sugar Mills Limited.

The whistleblower may report or raise any concern which he/ she believes is unethical or contradictory to the code of conduct of the organization, which may include the following acts.

• Fraud
• Financial malpractice
• Failure to comply with applicable legal requirements or company policy.
• Improper conduct or unethical behavior, including breach of the company’s code of conduct, business integrity or ethics;
• Attempts to conceal any material facts or misrepresentation;
• Negligence causing substantial and specific danger to employees’ health, safety or environment;
• Any unlawful act whether criminal/civil;
• Colluding with third parties/associates to exploit or cause harm to the company;
• Manipulation of company data/ records;
• Unauthorized use, employees’ system password acquisition, access or disclosure of confidential/proprietary information;
• Abuse of authority;
• Misappropriation or unauthorized use of company funds/assets

All complainants are protected from victimization, harassment or disciplinary action as a result of any disclosure, where the disclosure is made in good faith and not maliciously or for personal gain. All disclosures are required to be made in writing. Disclosures made anonymously will not be entertained. Disclosures made will be investigated fully including interviews with all the witnesses and other parties involved. All whistle blowing disclosures made are treated as confidential and the identity of the whistleblower is protected at all stages in any internal matter or investigation.

Disciplinary action (up to and including dismissal) may be taken against the wrongdoer depending on the results of the investigation.

An email address will be provided, which will be managed by the Chief Executive Officer and Chairman of the Board’s Audit Committee. Who shall examine the email and decide the appropriate steps required to be taken, if any.