In accordance with Halwani Bros Company strategy to adhere to the highest level of corporate governance and internal control, a Whistleblower program has been developed for immediate implementation, and will be fully controlled by Halwani Bros. Not only will the program offer confidentiality and protection of the Whistleblower, but will also be extended to recognition and appreciation, for fully proven cases

The program will help the company in the disclosure and reporting of any fraud, waste, violation of laws and regulations at any level of the organization. The reporting could be internal (from an employee) or external (from any stakeholder or third party)

We require specific, timely, factual details of your information for investigation, including the names of the individual(s) and/or firm(s) involved so we may take appropriate action. All information received will be treated confidentially to the fullest extent possible.

Whistleblowing is defined as making a disclosure “that the employee or any third party reasonably believes is evidence of any, ongoing or attempted fraud or theft, Management override, wasting resources, materials or FG and/or violation of the law and regulations within Halwani Bros. the below Examples are not limited to:

Forgery: is the act of reproducing something for a deceitful or fraudulent purpose. It can be an object, a document or some sort of statistical data for instance

A conflict of interest (COI): is a situation in which any HB person is involved in multiple interests, financial or otherwise, which will affect his official decision making process ,corrupting it to act towards his own personal gain rather than the organization’

Bribery: persuade or influence the actions of any HB official, by any employees, customers, suppliers, vendors, competitors, or agencies, or other parties by offering anything valuable, money, presents etc to influence his business decisions to their favor.

False representation: is the fraudulent practice of giving false information to others especially with an intension of making money or profit from it. Usually, false representations can be made by acts, words, or by any of the ways in which ideas may be communicated from one person to another.

Misuse of resources: The unauthorized, improper or unlicensed use of HB resources or properties by any HB employee for nonbusiness related purposes or reasons including incorrect use of systems and timekeeping.

Embezzlement: is the act misusing or misappropriating money/assets left to one’s care either to be held or to be used for specific purposes. Embezzlement is a type of financial fraud.

Theft: is the actual act of committing physical fraud, by taking physically money or any other assets belonging to HB with the intend of earning any physical or financial gain from this act.

HB’s Internal Audit Department shall handle and collect the required information from the whistleblower. HB’s Internal Audit Department will provide all the necessary means and support to all the prospected whistleblowers and all information will be treated with strict confidentiality.