Whistle Blower Policy
The Reload Logistics Group (“Reload”) strictly abides by its values to ensure ethical conduct and commitment to honesty, integrity and an open and diverse corporate culture.
As part of this commitment, Reload wishes to establish an environment in which an employee, director, client, supplier (including operational supplier, agent, banking institution, underwriter and IT service provider), investor (including shareholder), member of the community, member of the public, any other stakeholder of Reload or any other interested party whether internal or external to Reload (“Interested Party”) feel able to report suspected violations of these laws, regulations or any other concerns of malpractice in good faith and without fear of discrimination or retaliation.
This Whistle Blower Policy applies:
In all instances where an Interested Party wishes to report concerns or information regarding Reload in the following
categories:
- a violation of law or regulation by the company,
- financial malpractice,
- a danger to public health or safety,
- a gross mismanagement, and/or
- any other serious matter considered to be a miscarriage of justice by the Interested Party.
The Interested Party may report the matter directly to the whistle blowing mailbox at trustline@reloadlogistics.com in terms
of this Whistle Blower Policy.
If the allegation or complaint falls within the above categories, the designated Reload officer shall investigate the matter or,
where necessary, appoint an independent investigator to investigate the allegation or complaint.
If appropriate and necessary, the abovementioned Reload officer shall advise the external auditors of the Company, a
relevant government department, the police or any other relevant body.
The Reload officer shall oversee any investigation until the matter is fully resolved.
A genuine protected disclosure communication sent in terms of this Whistle Blower Policy shall be treated as confidential and any Interested Party, who has made a protected disclosure, shall be protected from consequential operational detriment and prosecution by Reload.
Objective
To establish a procedure that encourages and facilitates ‘whistle blowers’ to report genuine concerns about suspected misconduct or misdemeanours within Reload.
To provide a channel for any Interested Party to report complaints, allegations or concerns which fall within the categories set out in this policy.
To protect Interested Parties, who provide genuine protected disclosures, from consequential operational harm or prosecution by Reload.
To adhere to the applicable legislation as amended from time to time.
Procedure
Any Interested Party who wishes to report a genuine allegation or complaint regarding one of the abovementioned categories
shall follow the below procedure:
- email a formal statement to trustline@reloadlogistics.com.
- the statement should describe the allegation or complaint in detail and contain the relevant facts and names of
specific individuals involved if they are known. - the Reload officer shall consider the statement and investigate further.
- further clarity or explanation may be sought from the Interested Party by the Reload officer.
Malicious or dishonest disclosures will be investigated or reported by Reload for disciplinary action or prosecution where
necessary.
A genuine protected disclosure is a communication (by an Interested Party) which such Interested Party reasonably believes
will expose concerns or information regarding the categories set out above. Genuine protected disclosures are to be treated
as confidential.
The Interested Party who has made a protected disclosure shall be treated with respect and should be reassured that no
victimisation shall take place against them as a result of the disclosure. This includes protection from consequential
operational harm or prosecution by Reload. Applicable legislation, as amended from time to time, shall be adhered to.
The Reload officer shall investigate the allegation / disclosure and may appoint an independent investigator, if necessary and
appropriate to do so.
The Reload officer shall, if appropriate and necessary, advise the External Auditors of the Company, a relevant governmental
department, the police or any other relevant body as required.
The Reload officer shall ensure the appropriate follow-up action is put in place and the matter is fully reported and resolved.
It is specifically noted for employees that:
- The Whistle Blower process is for serious matters limited to the abovementioned categories.
- Employee grievances fall under a separate policy.
- Matters which do not fall within these areas shall be ignored.
- An Interested Party who makes dishonest or malicious allegations or disclosures (which do not comply with applicable law) shall be disciplined and, where appropriate, may face further action by Reload.
- Employees are encouraged to use ordinary communication channels to discuss any concerns or ideas falling outside the abovementioned categories.
Revisions to the Policy. Reload reserves the right to, and may from time to time, update this Policy. Any such revisions will be
published as an amended version and in such circumstances, Interested Parties agree to accept such reasonable revisions.
Do not hesitate to contact a representative of Reload should you have any questions or concerns or require any aspect of this
Whistle Blower Policy to be clarified or explained in further detail.