Whistleblowing Policy.

1. Introduction
AZADEA is committed to the highest possible standards of openness, integrity, and accountability. In line with that commitment, we encourage our applicants, clients, suppliers and contractors, with serious concerns about any aspect of the organization’s work, to come forward and voice those concerns.
2. Objectives
• To encourage you to transparently raise concerns about malpractice with concerned people at Azadea;
• To reassure you that your concerns will be taken seriously;
• To provide information about how to raise your concerns and explain how the company will respond;
• To promote a higher level of responsibility and accountability;
• To improve the internal control environment; and
• To help moving towards operational excellence.
3. Blowing the whistle on malpractice
Malpractice covers a wide range of concerns. The types of activities that should be disclosed include but are not limited to the following:
• Fraud or corruption
• Financial mismanagement
• Unauthorised use of public funds
• Physical, emotional or sexual abuse
• Failure to comply with legal obligations
• Endangering of an individual’s health and safety
• Damage to the environment
• Criminal offence
• Failure to follow financial and contract procedure rules
• Showing undue favour to a contractor or a job applicant
• Unfair treatment
• Deliberate concealment of information relating to any of the above.
4. Procedures
You should directly raise your concerns in writing by email to the Internal Audit department to the following address confidential@azadea.com as soon as you suspect malpractice. The Internal Audit department reports to the Audit & Risk Committee of Azadea group in this regard. Note that at all time your identity will remain strictly confidential unless you express otherwise. Remember that the earlier you raise concerns, the easier it will be to take action.
When reporting a concern, you should provide as much information and details as possible. In particular, you should provide the full names of the people involved or who know about what is happening; that might include the names of Azadea employees, applicants, clients, suppliers and contractors, dates of events and any relevant documentation. This will help the investigators to focus on the main issue quickly.
5. Confidentiality
AZADEA understands that you may be reluctant to come forward with information about a wrongdoing. As such, the company recognizes that most whistleblowers wish to raise concerns in confidence, which is ensured by the confidential process followed by the independent auditors.
6. Protection for the Whistleblower
All concerns raised under these procedures will be treated seriously and a decision will be made about whether or not an investigation is appropriate. In some cases, the investigation may result in disciplinary proceedings.
The Board of Directors of AZADEA will not tolerate harassment or victimization and will take action to protect you if you have raised a concern in good faith. Any employee who is found to have victimized or harassed an applicant, client, supplier or contractor who has raised a concern will face disciplinary action.
7. Allegations not made in Good Faith
Concerns that are raised frivolously, maliciously, for personal gain, or where they are known by the whistleblower to be untrue will be reported to the relevant contract manager/superintendent in order to take appropriate action.