Whistle-blowing Policy

A.1. In the pursuit of ensuring that its business is conducted in the highest standards of fairness, transparency, accountability, and ethics as embodied in the Code of Business Conduct and Ethics, ARTHALAND should adopt procedures for Officers and Employees and other interested parties to communicate concerns regarding ARTHALAND and its subsidiaries’ internal controls, accounting or auditing matters, and malpractice or wrongdoing that affects its stockholders and stakeholders. These procedures should provide a method of properly addressing concerns that individuals within ARTHALAND might have, while also offering whistle blowers protection from victimisation, harassment or undue disciplinary proceedings.

 

A.2. As a matter of procedure, all concerns relating to internal controls, accounting and audit matters, malpractice or wrongdoing, should be communicated to the Compliance Officer, who will disseminate to the Audit Committee at each of its meetings. Should the concern involve the Compliance Officer, then, communication may be directed to the President & CEO, who should likewise forward and present to the Audit Committee.

 

A.3. All communications received by the Compliance Officer/President & CEO should be kept confidential. Any employee can communicate the concern on an anonymous basis. The whistle blower should be kept informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions.

 

A.4. The Audit Committee should determine whether any action or response is necessary or appropriate in respect of a communication, and it will take or direct such action as it deems appropriate. Such action, which may involve the engagement of external advisers, may be categorized as a legitimate concern, misdirected or those that involve employee complaints or employment disputes, no further action is required as the concern can be analysed on its face, and further action or investigation is required. Any progress or update on ongoing investigations or analysis should be reported to the Audit Committee on a monthly basis or at such frequency as the Audit Committee may require.

 

A.5. Misdirected communications as determined by the Audit Committee should be addressed to the Human Resources Department and should be resolved following the processes contained in the Committee on Decorum and Investigation and Employees Code of Conduct and Ethics.

 

A.6. ARTHALAND should not tolerate any retaliation in any form against any employee who, in good faith, raises a concern or reports a possible legal or ethical violation under the Code. However, any individual found responsible for making allegations maliciously or in bad faith should be subject to disciplinary action.

 

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