Whistleblowing Policy

Whistleblowing Policy

This policy deals with concerns raised by employees / suppliers / customers / trade unions (hereinafter referred to as the Whistleblower) relating to unfair treatment, unfair practices, fraud, corruption, misconduct and malpractice within the Company. The policy will not apply to personal grievances which must be dealt with in terms of the Company Grievance Procedure.

The policy covers all genuine concerns raised including financial misconduct, health and safety issues, environmental damage, corruption and misconduct.

Any Whistleblower who has a reasonable belief that there is corruption or misconduct relating to any of the above matters may raise a concern without malice and in good faith utilising the whistleblower procedure. Concerns may be raised against any level of employee / supplier or management or group of employees / suppliers or managers.

The Company commits itself to encourage a culture of openness but will ensure that any Complainant who discloses any of the above matters will not be penalised or suffer any occupational detriment for doing so.

Because of protection offered to Whistleblower raising a bona fide concern, it is preferable that the Whistleblower put his/her name to the disclosure to discourage unfounded disclosures. However, the Company will not disclose names of Whistleblowers without their consent. The Company will not tolerate the harassment or victimisation of any Whistleblower raising a valid/genuine concern.

The Company, however, recognises that Whistleblower may wish to make disclosures in confidence. All disclosures will receive equal treatment.

Procedure

 A Whistleblower who wishes to report an incident in terms of the Whistleblowing Policy and Procedure must:

1. Call the Whistleblowing hotline at 0829970369 OR complete the Whistleblowing Form, here and e-mail it to PrideMillingIR@mweb.co.za.
2. Furnish the independent Whistleblowing Agent with as much as possible details to ensure that an effective investigation can be conducted regarding the following:
   • Who is involved?  What are the names of the individuals/businesses, who owns them, and where are they located?  Who else knows about the improper activities?  Who can and would confirm that they occurred?  How can we reach these witnesses? 
   • What specifically did the suspect do?  What is wrong with it?  What kind of documents would provide evidence of the improper activities?  Where are the documents located?  Who controls them? 
   • Where did the action happen? 
   • When did the improper activity occur?  Is it ongoing?  How frequently has it occurred? 
   • What are the suspect(s) motives?  For example, how does the suspect benefit?  If others benefit from the activities, who are they and how do they benefit? 
   • How did the wrongdoing occur?  Was there a lack of controls, circumvention of controls, or collusion with other individuals?
3. The independent Whistleblowing Agent will ensure that the Whistleblower’s details remain undisclosed.
4. The independent Whistleblowing Agent, after validating the complaint, will ensure that the matter is recorded at the Social and Ethics Committee (SEC).
5. The SEC shall decide on appropriate action and shall give feedback to the Whistleblower.
6. The SEC shall ensure that appropriate record is kept of:
   • The date the matter was reported.
   • The nature of the matter.
   • Appropriate action implemented to address the matter.
   • The date the matter was resolved/ addressed.
   • The date feedback was given to the Whistle-blower.
   • If no feedback was given, reasons why feedback was not given to the whistle-blower.

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