Whistleblower Policy

The Whistleblower Policy is a procedure that has been established to provide employees and other stakeholders (suppliers/customers) with a method of reporting their concerns regarding Company issues they feel they cannot raise with their line manager. They can use this process to report it either online or by confidential mail and it will then be investigated by the Chairman of the Audit Committee. Scope

The Whistleblower Process is intended for the reporting of concerns with regard to possible irregularities in accounting, auditing or banking matters or bribery within the business of Emirates Steel, and not for general business complaints or product issues or grievances about an employee's personal employment situation.

Reports
If an employee or any other stakeholder (customer, supplier) of Emirates Steel has a concern about possible malpractice falling within the scope of this Whistleblower Process, he/she should raise it in the first instance with his/her direct supervisor, a member of management team or with the head of the Internal Audit Department at ADBIC or GHC. However, if this person is concerned about the response or lack of response, or if he/she feels unable to talk to his/her supervisor or anyone else mentioned above, he/she can use the Whistleblower Process.

Treatment of Reports Any employee or stakeholder may use the email address esiwhistleblower@ghc.ae to raise alarms to the Internal Audit Department of ADBIC/GHC" with regard to the issues discussed above.

Treatment of Reports
Reports received will immediately be distributed to the Chairman of the Audit Committee.

Any reports not related to accounting, financial auditing or banking matters or bribery will be disregarded when reported through whistle blowing channels, except when they relate to serious facts, i.e., when they affect the key interests of Emirates Steel or its employees' integrity or physical or mental wellbeing will be forwarded to the CEO by the Chairman of the Audit Committee.

If the report falls within the scope of the Whistleblower Process, the Chairman of the Audit Committee will either instruct the Internal Audit Department to conduct an investigation or instruct the CFO to ask the relevant Department of Emirates Steel to prepare a written report.

The CEO will promptly inform any employee who is alleged to be involved in an accounting, financial auditing, banking or bribery issue of the facts alleged against him/her, as well as how to exercise his/her rights of access and correction. Such notice may be deferred for a very limited time period in order to secure any potential evidence.

All reports will be dealt with as soon as reasonably practicable, taking into account the complexity and the nature of the report.

In cases where there is a legal obligation to communicate the information to public bodies responsible for the prosecution of crimes, the Chairman of the Board of Directors will instruct the CEO to forward the report to the relevant competent authority.

Investigation Result
All reports made through the Whistleblower Process will initially be tabled to the Audit Committee with a summary report being forwarded to the Board of Directors at a later date as appropriate. All results of investigations conducted by the Internal Audit Department or written reports prepared at the request of the CEO will be tabled at the next meeting of the Board. The Internal Audit Department will decide on the next steps based on the result of the investigation and may decide either to make further investigations or to make recommendations to the Board of Directors for process improvements or corrective actions.

Feedback
The employee who submitted the report will receive feedback about how the report has been dealt with (unless instance is reported anonymously), whether any corrective measures or process improvements have been recommended and if any further steps will be taken. No details will be released relating to specific individuals and the feedback might be of a general nature, taking into account the interest of Emirates Steel to keep its information confidential and the rights of any third parties.


Confidentiality
The reports will be disclosed only to the employees who have a "need to know" for the purpose of the investigations. All employees involved in the Whistleblower Process will maintain strict secrecy about the content of any reports made in accordance with applicable law. Any disclosure of reports or results of investigations will be authorized by the Chairman of the Board or the by the Board of Directors.

Non Retaliation
Emirates Steel will take the necessary measures to protect employees and other stakeholders who have, in good faith, made reports through the Whistleblower Process, against any retaliation from managers or other involved parties.

Document Retention
The Chairman of the Audit Committee will maintain a record of all reports, tracking their receipt, investigation and resolution.

Statistical information and data relating to the types of reports received and corrective measures taken will be maintained for a minimum of 5 years from the closing of the investigation, except where otherwise required by local law.
Data relating to a report that is found to be unsubstantiated will be deleted without delay. Data relating to a report that is found to be substantiated will be deleted within two months after the investigation is closed, unless a disciplinary procedure or legal proceeding is initiated against the person incriminated in the report or the author of an abusive report.

Any employee has the right to access and correct his or her personal data, including any information available in the record of reports, and may do so by contacting the Chairman of the Audit Committee. However, the name of the person who submitted a report will not be communicated to the accused person by the Company.