Interstate Securities Limited (“ISL”/”the Company”)) requires Directors, Officers and Employees to observe high standardsof business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of ISL must practice honesty andintegrity in fulfilling their responsibilities and must comply with all applicable laws andregulations.
This Policy establishes Guidelinesfor managing a whistle blowing mechanism for reporting wrongdoing within the Company.
2. Objectives
The Whistleblower Policy is intended to encourage and enable employees and stakeholderssuch as contractors, shareholders, job applicants, and the general public to raiseserious concerns internally to enable ISL address and correctinappropriate conduct and actions. It is the responsibility of all Board members, officers,employees and volunteers to report concerns about violations or suspectedviolations, of law or regulations that govern the Company’s operations. Efforts will be made to bring the existence of the Company’s Whistle Blowing mechanism to the knowledge of all staff and other stakeholders, including through inclusion on ISL’s Website.
3. No Retaliation
It is contrary to the values of ISL for anyone to retaliate against any person who in good faith reports an ethics violation, or asuspected violation of law, such as a complaint of discrimination, or suspected fraud, orsuspected violation ofany regulation governing the operations of the Company.
4. Whistle Blowing Procedure
All Whistle blowing complaint shall be lodged through the Company’s website and not from a complainants’ personal email in order to guarantee the anonymity of the complainant. The following officers shall be recipients of the whistle blowers’ email messages:
The Chairman of the Board Governance Committee.
The Managing Director/CEO
The Board shall have the responsibility to support the Company’s whistle-blower protection mechanismfor reporting any illegal or substantial unethical behavior which shall be accorded priority by the Board.
5. Lodgment of Complaints
The Managing Directorshall consult with the Chairman of the Board Governance Committee on the line of action to take. In situations where information is received and the Managing Director/CEO does not initiate the process of investigation, the Chairman of the Governance Committee may initiate the investigating process. A Whistleblowers Report shall be compiled from time-to-time and at least Quarterly and reported to the Board Governance Committee.
6. Good Faith
Any person filing a written complaint concerning a violation or suspected violation must act in good faith and have reasonable grounds for believing the information disclosedindicates a violation.
