See Something, Say Something.
If you suspect or observe any irregularities relating to accounting, accounting internal controls, or auditing matters, or if you think that an actual or possible violation of this Code or other policies or other unlawful or improper workplace conduct has occurred, it is important to report your concerns immediately. You should use the channel that is most comfortable to you. As a general matter, your supervisor or manager may be in the best position to address an issue. However, that is not your only option. Potential channels to report a concern include your manager, the Company’s legal division, including the General Counsel, and where appropriate, the Audit Committee pursuant to the Company’s Whistleblower Policy.
We also have in place a whistleblowing contact and consultation contact pursuant to “Whistleblower Policy” where reports or consultation can be made at any time by chat, phone, e-mail, facsimile, document, or direct meeting.
The Company strives to ensure that all questions or concerns are handled fairly, discreetly, and thoroughly.
Once a report is made and received, the Company will investigate promptly and all directors, officers, and employees are expected to cooperate candidly with relevant investigatory procedures. If, after investigating a report of an alleged prohibited action by a director or executive officer, the Audit Committee determines that a violation of this Code has occurred, the Audit Committee will report such determination to the Board.
If, after investigating a report of an alleged prohibited action by any other person, a relevant manager determines that a violation of this Code has occurred, the manager will report such determination to the General Counsel.
Upon receipt of a determination that there has been a violation of this Code, the Board or the General Counsel, as appropriate, will take such preventative or disciplinary action as it deems appropriate, including, but not limited to, reassignment, demotion, dismissal and, in the event of criminal conduct or other serious violations of the law, notification of appropriate governmental authorities.
The Company has a no-tolerance policy for retaliation against persons who raise good faith compliance, ethics, or related issues. However, it is unacceptable to file a report knowing it to be false.
For more information regarding reporting concerns of possible violation and misconduct, please review the Company’s Whistleblower Policy.
Contact our team at IR@namibminerals.com.