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Grievances and Whistleblowing Policy

Al Etihad Gold is fully committed in providing high quality products and services while meeting the highest ethical and moral standards.

We are fully committed to:

• Follow the rules and law that regulates our business activities.
• Follow international best practices and market standards applicable to our business.
• Operate in accordance with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and its Supplement on Gold; and the DMCC Rules for Risk Based Due Diligence in the Gold and Precious Metals Supply Chain.

Guideline for Reporting:

1. Who can report?

Employees, clients and customers, end-users and other affected stakeholders can use the Grievances and Whistle-blowing Policy.

2. What can be reported?

We encourage stakeholder to raise concerns and disclose information about a suspicion or knowledge of a wrongdoing which may include but not limited to:

(a) Financial malpractice, impropriety or fraud; bribery, corruption and solicitation;
(b) Failure to comply with a legal obligation or applicable laws;
(c) Human rights abuses (including dangers to health and safety or the environment);
(d) Criminal activity;
(e) Improper conduct or unethical behaviour;
(f) Attempts to conceal any violations of the DMCC Rules and Regulations or the DMCC Anti-Money Laundering /Counter Financing of Terrorism (AML / CFT) Policy or DMCC Rules for RBD-GPM;
(g) Falsification of documents or fraudulent suppliers; and
(h) Direct or indirect violations of the DMCC Rules and Regulations or the DMCC AML/CFT Policy or DMCC Rules for RBD-GPM…etc.

3. How should the report be made?

The reporting person may choose to remain anonymous when disclosing information or claim. The reports can be submitted to the following email address: compliance@aletihadgold.com. We encourage that the report be evidenced base and provide as much information as possible to aid the investigation. If substantiated, appropriate action and communication will be done to concerned parties and may be reported to the regulators.

4. How we are addressing reports?

If the reporting person chose to report with his identity, we guarantee to keep the identity confidential and process any personal data collected through the report fairly and lawfully for the sole purpose of identifying and investigating allegations of illegal activities or non-compliances to Al Etihad Gold policies.

Al Etihad Gold guarantees that the reporting person shall not in any way be prejudiced, reprimanded and will not tolerate any form of retribution against a person for raising a concern. For employees of Al Etihad Gold, the HR and the Managing Director shall adequately instruct and supervise sanctions against employee retaliation.
All reports shall be acknowledged, recorded and investigated without undue delay, provided that the report is considered to be made in good faith. Where possible, the reporting person shall be kept updated on the progress of the investigation. The reporting person will be informed to whom the complaint is referred to, the timeline and outcome of the investigation.

5. Evaluation, Review and Lessons Learned:

Al Etihad Gold shall conduct periodic audits of the Grievances and Whistleblowing mechanism. The review shall include records of the numbers, type and outcome of complaints, and appropriate corrective actions made, if necessary.





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