Whistleblowing Policy:

Introduction

Kromco is committed to high standards of ethical and legal business conduct. In line with this commitment, and Kromco’s commitment to open communication, this policy is intended to foster and maintain an environment in which employees can express their concerns, without fear of punishment, victimisation or unfair treatment, and ultimately assist in preventing corrupt behaviour within Kromco.

Scope

The policy applies to all staff (permanent and seasonal), contractors, visitors and service providers at Kromco at any of its facilities (physical or virtual).

Responsibility

The HR Department is responsible for reviewing and revising this policy and has overall responsibility for monitoring the arrangements in place.

What is Whistleblowing

Whistle blowing is the act of an employee raising their voice against specific concerns or unethical activities being carried out within the organisation. A whistle-blower is not an investigator or finder of facts, and the whistle-blower does not determine the appropriate corrective action that may be warranted.

Whistleblowing in good faith is in the best interest of Kromco. Good faith is evident when the report is made without malice or consideration or personal benefit and the whistle-blower has a reasonable basis to believe that the report is true.

Examples of the types of concerns that may be reported include, but are not limited to the following categories:

A bribe has been, is being or is likely to be paid or received by any person associated with Kromco;
Unlawful activities / criminal offences / Security activities;
Harassment or victimisation;
Activities that are not in line with the policies and codes of conduct of Kromco;
Falsification or false reporting of financial information;
Food Safety related issue.

Scope Exclusion

This policy does not apply to personal grievances concerning an individual’s terms of employment or other aspects of his or her working relationship with Kromco or disciplinary matters. Such matters should be reported as per the company’s grievance policy.

Whistle Blowing Safeguard

Harassment and Victimisation

Whistle-blowers should be aware that if they report an incident in good faith, they will have nothing to fear. Under this policy, harassment and victimisation of whistle-blowers will not be tolerated.

Anonymity and Confidentiality

Every effort will be made to treat the whistle-blower’s identity with the appropriate regard for confidentiality. Circumstances may however dictate that the identity of the whistle-blower may need to be revealed if for example, he or she must be called as a witness.

This policy provides for whistle-blowers to report incidents anonymously. Doing so will not preclude a report from being investigated. Concerns expressed anonymously will be explored appropriately, but consideration will be given to:

The seriousness of the issue raised,
The credibility of the concern, and
The likelihood of confirming the allegation from attributable sources.

Bad Faith Allegations

Allegations made maliciously and in bad faith may result in disciplinary action.

Encouragement and Recognition

Employees are frequently encouraged to report any wrongdoing either in person, through different methods or through anonymous boxes. Employees who report any activity / wrongdoing are recognised on continuous bases.

Process for raising a concern

Employees are encouraged to use any of the communication methods detailed below:

Method of communication	Contact Details
Telephone	021 850 6700
Email	tipoffsanonymous@kromco.co.za
Anonymous Boxes	Locations: Packhouse - Canteen Entrance Ground Floor, Clinic - Next to Entrance Admin Block - Parking Bay (Next to Entrance to HR Department)
Website	www.kromco.co.za
Post	PO. Box 133, Grabouw, 7160