Internal Audit Department

The Company's employees are encouraged to speak up and report their concerns so that problems can be resolved thereby preventing any harm that might occur. Employees are expected to report concerns about any misconduct or dishonest or illegal activities or the employee suspects is occurring within the Company. This reporting can be done through a number of channels on a confidential and anonymous basis as described below.

What is Whistleblowing?

Whistleblowing is the confidential or anonymous disclosure by an individual of any concern encountered in the workplace relating to a perceived wrongdoing. Wrongdoing include, but are not limited to:

non-compliance with the provisions of this Code;
any immoral, illegal or unethical conduct;
any conduct which puts someone’s health and safety in danger;
any violation of laws, rules or regulations;
violation of any internal policy or procedure;
acts of fraud, money laundering or bribery;
falsification or misrepresentation of financial information; or
harassment or discrimination against any employee.

How to Make a Report?

The report must be made in good faith. It should be clear, factual and not misleading.

Methods of reporting: There are several ways in which employees can report their concerns:
1. by sending an e-mail using a free e-mail account that does not reveal the employee’s name or any other personal information;
2. anonymously sending a written letter; or
3. by making calls or attending meetings with the Head of Internal Audit on a confidential basis; in this case the name of the employee will remain strictly confidential and will not be revealed without his/her permission.
What to include in a report: The report; whether verbal or written, must include all of the following information:
1. the type of wrongdoing you would like to report;
2. where it took place/has taken place or is currently taking place?;
3. when did/does it take place?; and
4. a full description of the wrongdoing, names of individuals involved or suspected to be involved, together with supporting documentation if available.
What are the contact details to which a report should be submitted:
1. Any employee discovering/encountering fraud, malpractice or misconduct can raise a concern through:
  1. Email: contact.whistleblowing@depa.com. Access to this email will be restricted to the Audit & Compliance Committee Chairman and Head of Internal Audit.
  2. Telephone: the employee can directly approach the Head of Internal Audit on his mobile number or through the Company landline.
  3. Letter: letters can be addressed to the Head of Internal Audit.
2. In case the misconduct investigation is in relation to the Head of Internal Audit, the notification can be made to the Audit and Compliance Committee chairman.
3. The Head of Internal Audit shall notify the Compliance Governance Manager on receipt of any fraud notification after obtaining due approvals from the Audit and Compliance Committee chairman to ensure compliance with the notification requirements as per the rules and regulations.

Protection for Whistleblowers

Confidentiality will be maintained to the fullest extent possible, the Company will protect from admonishment, disciplinary action or retaliation of any employee, who in good faith, reports a wrongdoing.
The communication that is directly made with the Head of Internal Audit will report to the Audit & Compliance Committee which does not include any personnel from the executive management of the Company including the CEO. Hence employees are encouraged to send emails directly with appropriate documentation/proof where available. It is the employee’s decision to remain anonymous.
In cases where legal action has been initiated, the employee may be required to stand as a witness in accordance with the laws and regulations.