Policies

Food Safety and Quality Policy

At UPP we are passionate about growth through quality innovation and service to our customers.

The aim of UPP is to meet its obligations to provide the highest level of food safety and quality to all their customers. We are committed to manufacturing, packaging and delivering safe and legal products, at all times to our customers. We will continually endeavour to improve our processes and food safety standards, through an efficient, effective and suitable food safety management systems.

Manufacturing at our facility at UPP, Agri-Tech Centre, Poultry Lane, Telford, TF10 8JZ is carried out in line with the standards of food hygiene and established by the principles of Codex Alimentarius and the seven key principles of (HACCP) Hazard Analysis Critical Control Points. As well as the requirements of BRCGS Standard for Food Safety Issue 9 2022, BRCGS Plant Based and in-line with the standard of our customers and current legislation.

Where required, Critical Control Points will be set and measures introduced to manage these control points in order to eliminate or minimise the risk of contamination during our manufacturing and packaging processes. These procedures are documented within our HACCP Manual, alongside any potential contamination risks and associated critical limits.

The company’s Food Safety Management System is fully implemented by the company and is maintained by a multi-disciplinary team. Developing and establishing verified procedures, with ongoing validation of the control measures. These processes are the implementation of operational pre-requisite programmes and analytical and microbiological analysis.

All food safety hazards, that may reasonably be expected to occur, are identified by this process and are then fully evaluated and controlled so that our products do not represent a direct or indirect risk to the consumer.

Our food safety performance will be evaluated annually by the HACCP team and documented through our HACCP meetings. Reviewing this policy, production line records and results, as well as any customer complaints. Food industry developments and changes to legislation, will also be captured and incorporated into our system. Ensuring that the company continues to develop the highest food safety standards.

Fraud (TACCP & VACCP) such as substitution or deliberate and intentional adulteration has been considered separate to the HACCP plan and can be found with the Vulnerability Assessment File. Malicious contamination of products has also been considered separately from the HACCP plan and can be found within the Site Security Risk Assessment File.

The potential risk for adulteration or deliberate contamination is very difficult to quantify in a meaningful way. However, this risk is minimised by pre-requisite programmes and HR procedures. Which is used to assess potential employees and temporary personnel, combining an extensive training programmes, on-line supervision, tamper evident packaging, CCTV monitoring, entry point door control via keypads and out of hours on-site security.

Identified hazards are assessed for their potential threat to food safety and subjected to the controls documented within each HACCP plan.

Food Safety and Quality is everyone’s responsibility; all colleagues have a role to play. For our part the company will be:

a) taking accountability for the effectiveness of the quality management system;

b) ensuring that the quality policy and quality objectives are established for the quality management system and are compatible with the context and strategic direction of the organisation;

c) ensuring the integration of the quality management system requirements into the organization’s business processes;

d) promoting the use of the process approach and risk-based thinking;

e) ensuring that the resources needed for the quality management system are available;

f) communicating the importance of effective quality management and of conforming to the quality management system requirements;

g) ensuring that the quality management system achieves its intended results;

h) engaging, directing and supporting persons to contribute to the effectiveness of the quality management system;

i) continual improvement of the quality management system;

j) Supporting other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility;

k) providing services focused on the needs & expectations of our Clients, as well as satisfying statutory & regulatory requirements;

The policy and procedures described in the Quality Manual conform to the requirements of the British Standard for quality management systems i.e. BS EN ISO 9001 and BRCGS.

Modern Slavery Policy

1. Overview and how we define Modern Slavery

1.1 Slavery, forced labour, servitude, and human trafficking are types of ‘Modern Slavery’ – criminal activity that deprives victims of their liberty and usually involves financial and other exploitation.

1.2 We conduct our business fairly, ethically and with respect to fundamental human rights. We are committed to the prevention of all forms of Modern Slavery, both in our business and in our supply chains. We will not tolerate it.

1.3 You must read and comply with this policy if you work for, or on behalf of us in any capacity including as: an employee, director, officer, worker, consultant, volunteer, supplier or service provider.

1.4 Failure to comply with this policy may result in disciplinary action, including dismissal, or termination of the contract between you and us. It could also involve other legal steps being taken against you.

1.5 Our Anti-Slavery Officer (‘ASO’) is Mark Evans. They are responsible for this policy.

1.6 If you are an employee, this policy does not form part of your employment contract, and we may update it at any time.

2. Preventing Modern Slavery in our business

2.1 We carry out appropriate checks on all employees, recruitment agencies and suppliers, so that we know who is working for us or on our behalf.

2.2 We give every employee a written employment contract, and he or she is paid in accordance with the law. We comply with our legal obligations to ensure the health and safety of all of our employees and workers, including in relation to working hours, rest breaks and holidays.

2.3 All employees are required to sign a copy of this policy to show they have read and understood it

3. If you are one of our Suppliers

3.1 If you supply us with goods or services, you must assess your business and supply chains and confirm to our ASO that you:

• Comply with your legal obligations, in relation to Modern Slavery; and

• Are committed to ensuring there is no Modern Slavery taking place in your business, or in any of your supply chains.

You must also provide a copy of your anti-slavery policy.

3.2 If you breach this policy or are found to have Modern Slavery in your business, or knowingly in your supply chain, we may terminate our contract with you and pursue legal remedies against you.

4. If you are an Employee or a Worker providing services for us

4.1 You must immediately report any suspicions of Modern Slavery in our business or supply chains to our ASO. Our ASO will investigate and report to our Board of Directors within a reasonable time, on actions which may require to be taken.

4.2 You will not suffer any detrimental treatment as a result of reporting any genuine concerns, raised in good faith, under this policy. This applies, even if after investigation, they are found to be mistaken. If you believe that you have suffered any such treatment, you should immediately tell our ASO and, if you are an employee, refer to our Grievance and Whistleblowing Policies.

Environmental Policy

Purpose and Scope

Purpose: To minimise the environmental impact of our operations and promote sustainable practices in the production of alternative proteins.

Scope: This policy applies to all employees, contractors, and stakeholders involved in our operations.

Sustainable Sourcing

Raw Materials: Source vegetable side-streams from local, sustainable farms to reduce transportation emissions and support local agriculture.

Suppliers: Aim to partner with suppliers who adhere to sustainable practices and have certifications such as BCERT, organic or fair trade.

Energy Efficiency

Renewable Energy: Utilise renewable energy sources (e.g., solar, wind) for production facilities where possible.

Energy Management: Implement energy-efficient technologies and practices to reduce overall energy consumption.

Waste Management

Reduction: Minimise waste generation through efficient production processes.

Recycling and Reuse: Implement a robust recycling program and find innovative ways to reuse by-products.

Water Conservation

Efficient Use: Use water-saving technologies and practices in production.

Recycling: Aim to treat and recycle water used in the production process.

Carbon Footprint Reduction

Emissions Tracking: Regularly monitor and report greenhouse gas emissions following the convent of harvest and protein production operations.

Offset Programs: Look to invest in carbon offset programs to neutralise unavoidable emissions.

Product Lifecycle Management

Eco-friendly Packaging: Use sustainable packaging materials where possible.

End-of-Life: Design products with their end-of-life in mind, ensuring they can be easily recycled or composted where possible.

Employee Engagement and Training

Awareness Programs: Conduct regular awareness sessions on sustainable practices and the importance of environmental stewardship.

Incentives: Encourage employees to participate in sustainability initiatives through incentives and recognition programs.

Compliance and Continuous Improvement

Regulatory Compliance: Ensure all operations comply with local, national, and international environmental regulations.

Continuous Improvement: Regularly review and update the environmental policy to incorporate new technologies and practices.

Community and Stakeholder Engagement

Transparency: Maintain open communication with stakeholders about environmental performance and initiatives.

Community Involvement: Engage with the farming community with which we work.

Implementation and Monitoring

Implementation Plan: Develop a detailed plan outlining the steps and resources needed to implement this policy.

Monitoring and Reporting: Establish metrics to monitor progress and report on environmental performance regularly.

Information Security Policy

Purpose and Scope

Purpose: To protect personal data and ensure compliance with GDPR by implementing appropriate technical and organisational measures.

Scope: This policy applies to all employees, contractors, and third-party service providers who handle personal data.

Data Protection Principles

Lawfulness, Fairness, and Transparency: Ensure personal data is processed lawfully, fairly, and transparently.

Purpose Limitation: Collect personal data for specified, explicit, and legitimate purposes.

Data Minimisation: Ensure personal data collected is adequate, relevant, and limited to what is necessary.

Accuracy: Keep personal data accurate and up to date.

Storage Limitation: Retain personal data only as long as necessary.

Integrity and Confidentiality: Process data securely to protect against unauthorised or unlawful processing, accidental loss, destruction, or damage.

Roles and Responsibilities

Data Protection Officer (DPO): The CTO, who serves as our DPO, will oversee the strategy and implementation of data protection.

Employees: Ensure all employees are trained on GDPR compliance and data protection practices.

Third-Party Processors: Ensure third-party processors comply with GDPR requirements.

Data Security Measures

Access Control: Implement strict access controls to ensure only authorised personnel can access personal data.

Encryption: Use encryption to protect personal data both in transit and at rest.

Pseudonymisation: Where possible, use pseudonymisation to enhance data security.

Regular Audits: Conduct regular security audits to identify and mitigate vulnerabilities.

Incident Response: Develop and maintain an incident response plan to address data breaches promptly.

Data Subject Rights

Right to Access: Ensure data subjects can access their personal data upon request.

Right to Rectification: Allow data subjects to correct inaccurate or incomplete data.

Right to Erasure: Implement procedures to delete personal data upon request, where applicable.

Right to Restrict Processing: Allow data subjects to restrict the processing of their data under certain conditions.

Right to Data Portability: Enable data subjects to receive their data in a structured, commonly used, and machine-readable format.

Right to Object: Respect data subjects’ rights to object to data processing for specific purposes.

Data Breach Management

Detection and Reporting: Implement systems to detect and report data breaches promptly.

Notification: Notify the relevant supervisory authority within 72 hours of becoming aware of a breach. Inform affected data subjects without undue delay if the breach is likely to result in a high risk to their rights and freedoms.

Documentation: Maintain records of all data breaches, including details of the breach, its effects, and remedial actions taken.

Training and Awareness

Employee Training: Conduct annual training sessions on data protection and GDPR compliance.

Awareness Programs: Implement ongoing awareness programs to keep data protection top of mind for all employees.

Corporate Social Responsibility (CSR) Policy

Purpose and Scope

Purpose: To outline our commitment to ethical practices, environmental sustainability, and positive social impact.

Scope: This policy applies to all employees, contractors, and stakeholders involved in our operations.

Environmental Sustainability

Sustainable Sourcing: Source vegetable side-streams from local, sustainable farms to reduce our carbon footprint and support local agriculture.

Energy Efficiency: Utilise renewable energy sources and implement energy-saving technologies in our production processes.

Waste Management: Minimize waste through efficient production processes and implement robust recycling and reuse programs.

Water Conservation: Use water-saving technologies and practices, and recycle water used in production.

Social Responsibility

Community Engagement: Engage with local communities through working with local farms

Employee Well-being: Foster a safe, inclusive, and supportive work environment. Provide opportunities for professional development and ensure fair labour practices.

Product Safety and Quality: Ensure our products meet high safety and quality standards, contributing to public health and well-being.

Ethical Business Practices

Transparency: Maintain open and honest communication with stakeholders about our business practices and CSR initiatives.

Compliance: Adhere to all relevant laws and regulations, including environmental, labour, and ethical standards.

Fair Trade: Ensure fair trade practices in our supply chain, supporting ethical treatment of suppliers and workers.

Innovation and Continuous Improvement

Research and Development: Invest in R&D to develop sustainable and innovative products that meet market needs while reducing environmental impact.

Continuous Improvement: Regularly review and update our CSR policy to incorporate new technologies, practices, and stakeholder feedback.

Stakeholder Engagement

Customer Engagement: Educate customers about the benefits of alternative fibre sources and our commitment to sustainability.

Supplier Partnerships: Collaborate with suppliers who share our commitment to ethical and sustainable practices.

Investor Relations: Communicate our CSR efforts and achievements to investors, highlighting our commitment to long-term sustainability and ethical business practices.

Standard purchase terms

Definitions:

Buyer: The company purchasing the goods or services i.e., Upcycled Plant Power ('UPP') Limited Company number: 14171122

Supplier: The entity providing the goods or services.

Goods: The items being purchased.

Services: The services being provided.

Order Acceptance:

All Orders of value of £200 or more, or equivalent in other currencies, require a Purchase Order

Orders must be accepted in writing by the Supplier.

Any changes to the order must be agreed upon in writing.

Delivery:

Goods must be delivered by the specified date. If no date is stated the default date is within 30 calendar days of issue of Purchase Order.

Delivery terms (e.g., Delivery Duty Paid (DDP) Incoterm 2020) should be clearly stated.

The Supplier is responsible for obtaining necessary export/import licenses.

Price and Payment:

Prices are exclusive of VAT but inclusive of all other duties and taxes.

Payment terms (e.g., 60 days from the date of invoice) should be specified.

The Buyer may withhold payment if the Supplier fails to meet contractual obligations.

Risk and Title:

Risk and title pass to the Buyer upon delivery.

The Supplier must ensure that goods are delivered in good condition.

Warranties:

Goods must comply with specifications and be of satisfactory quality.

The Supplier warrants that the goods are fit for the intended purpose.

Liability:

The Supplier is liable for any damage caused by defective goods.

Limitations on liability should be clearly defined and agreed in advance.

Termination:

The Buyer can terminate the contract for convenience with notice.

The Supplier is entitled to fair compensation for work-in-progress but not for anticipated profits.

Confidentiality:

Both parties must keep all information related to the contract confidential unless doing so would break the law.

Confidentiality obligations continue for three years after the contract ends.

Intellectual Property:

Any intellectual property created during the contract belongs to the Buyer.

The Supplier must not infringe on third-party intellectual property rights.

Dispute Resolution:

Disputes should be resolved through negotiation or mediation.

If unresolved, disputes may be referred to arbitration.

Governing Law:

The contract is governed by the laws of England and Wales.

Standard terms for sale of food ingredients

Definitions:

Seller: The company providing the food ingredients i.e., Upcycled Plant Power ('UPP') Limited Company number: 14171122

Buyer: The food manufacturer purchasing the ingredients.

Goods: The food ingredients being sold.

Order Acceptance:

Orders must be confirmed in writing by the Buyer in the form of a Purchase Order

Any amendments to the order require mutual written agreement.

Price and Payment:

Prices are exclusive of VAT but inclusive of all other taxes.

Payment terms (e.g., 30 days from the date of invoice) should be specified.

Late payments may incur interest charges at the Bank of England base rate + 5%

Delivery:

Delivery terms (e.g., Delivered Duty Paid (DDP) Incoterm 2020) should be clearly stated.

The Seller is responsible for ensuring timely delivery.

Risk and title pass to the Buyer upon delivery.

Quality and Inspection:

Goods must comply with agreed specifications and be of satisfactory quality for a 'low care' food ingredient

The Buyer has the right to inspect the goods upon delivery and reject any non-conforming goods.

Any issues relating to quality or non-conformance should be reported in writing within 2 working days of receipt

Warranties:

The Seller warrants that the goods are fit for the intended purpose and free from material defects.

The Seller must comply with all relevant food safety and regulatory standards.

Liability:

The Seller is liable for any damage caused by defective goods.

Liability is restricted to the value paid for the goods.

Force Majeure:

Neither party is liable for failure to perform due to circumstances beyond their control (e.g., natural disasters, strikes).

Confidentiality:

Both parties must keep all information related to the contract confidential unless doing so would break the law

Confidentiality obligations continue for three years after the contract ends.

Intellectual Property:

All intellectual property embodies in the products or services of the Seller remain the property of the Seller..

The Seller must not infringe on third-party intellectual property rights.

Termination:

Either party can terminate the contract for breach of terms with notice.

The Buyer can terminate for convenience with notice, subject to compensation for work-in-progress.

Governing Law:

The contract is governed by the laws of England and Wales.

Anti-Bribery and Anti-Corruption Policy

Introduction

At UPP, we are committed to the highest standards of ethical conduct, integrity, and compliance in all business relationships and activities. We conduct our business fairly, transparently, and in full compliance with applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act (FCPA), and in alignment with recognised ethical trade expectations such as BRCGS and SEDEX/SMETA.

This policy forms part of our governance framework and complements our existing Code of Conduct, Modern Slavery Policy, and other corporate policies.

Scope: This policy applies to:

a) All UPP employees, officers, directors, and contractors;

b) Third parties acting on behalf of UPP (including agents, consultants, intermediaries, partners, representatives, and suppliers);

c) All locations where UPP conducts business, whether in the UK, the US, or internationally.

Policy Statement: UPP takes a zero-tolerance approach to bribery and corruption. It is illegal to offer, promise, give, request, agree to receive, or accept a bribe in any form. All personnel and third parties must comply with this policy and all relevant laws.

A “bribe” includes cash or other financial advantages, gifts, hospitality, favours, kickbacks, facilitation payments, or anything else of value offered or received to influence a business decision, secure an improper advantage, or induce preferential treatment.

Legal Compliance: UPP and its personnel must comply with all relevant anti-bribery laws, including but not limited to:

UK Bribery Act 2010, which criminalises bribery in the public and private sectors and requires organisations to prevent bribery by associated persons; and

US Foreign Corrupt Practices Act (FCPA), which prohibits corrupt payments to foreign officials for business advantages.

Non-compliance may result in criminal penalties for individuals and UPP, including fines and imprisonment under applicable laws.

Responsibilities

UPP Board and Senior Management: Are responsible for oversight of compliance with this policy, embedding anti-bribery controls in governance, and providing necessary resources.

Compliance Officer: Will maintain this policy, oversee implementation, conduct risk assessments, coordinate training, and ensure reporting mechanisms are effective.

Employees and Third Parties; Must be familiar with, and comply with, this policy and report any suspected breaches. All personnel must complete mandatory anti-bribery training.

Gifts, Hospitality & Facilitation Payments: Gifts and hospitality can be legitimate but must never be offered, promised, given, or received if they could improperly influence business decisions. All such expenditures must be reasonable, proportionate, and transparent, with prior management approval where required. Facilitation payments are prohibited.

Third-Party Due Diligence and Controls: Before engaging third parties, UPP will conduct anti-bribery due diligence proportionate to the risk. We will:

• Assess third-party integrity, reputation, and compliance commitments;

• Include contractual anti-bribery obligations;

• Monitor and review third-party compliance periodically; and

• Require self-certification or updated information from high-risk third parties.

Financial and Record-Keeping Controls: UPP will maintain accurate books, records, and accounts that reflect all transactions and comply with legal requirements. All invoices and expenses must be supported by valid documentation. Employees must not falsify records to conceal improper payments.

Reporting and Whistleblowing: UPP supports reporting of suspected breaches and prohibits retaliation. Employees, suppliers, and third parties should report concerns via established channels (e.g., compliance contact, anonymous reporting where available). Reports will be investigated confidentially and promptly.

Training and Awareness: UPP will provide regular training and communications to employees and relevant third parties on anti-bribery requirements, risk factors, and how to manage ethical dilemmas.

Breach of Policy: Violation of this policy may result in disciplinary action, including termination of employment or contracts, and may also lead to legal action. UPP will cooperate with enforcement authorities where required.

Monitoring and Review: This policy will be reviewed at least annually and updated as necessary to remain aligned with evolving legal requirements (including UK, US, and international law), BRCGS expectations, and SEDEX/SMETA ethical trade standards.

Whistle-Blower and Grievance Policy

Policy Statement

UPP is committed to the highest standards of ethical conduct, transparency, and compliance with all applicable laws, internal policies, and internationally recognised ethical trade principles, including those used in SMETA/SEDEX audits. We encourage the reporting of concerns about misconduct, unethical behaviour, or violations of policy without fear of retaliation.

Purpose

This policy:

Provides a safe, confidential, and accessible mechanism for reporting concerns,

Promotes early identification and resolution of issues related to ethical, legal, health & safety, environmental, and labour practices,

Supports the company’s commitment to ethical business practices in line with UPP’s existing Modern Slavery, Corporate Social Responsibility, and other governance policies.

Scope

This policy applies to all employees, contractors, suppliers, temporary workers, agents, and others acting on behalf of UPP in any jurisdiction. It covers reporting of concerns relating to:

Ethical, legal or regulatory violations,

Labour rights abuses (including forced labour, discrimination, harassment),

Health & safety risks or unsafe practices,

Environmental compliance issues,

Financial irregularities, fraud, bribery, or corruption,

Any suspected retaliation against reporters acting in good faith.

Definitions

Whistle-blower/Reporter: Any individual who makes a report under this policy,

Good Faith: A report made with honest belief that the information is true, even if later proven incorrect,

Retaliation: Any adverse action taken against a reporter for raising concerns.

Principles

UPP will:

a) Safeguard the confidentiality of reporters to the fullest extent possible,

b) Protect reporters against retaliation or harassment,

c) Conduct impartial, thorough, and timely investigations,

d) Ensure appropriate corrective actions where concerns are substantiated.

Reporting Mechanisms

Individuals may raise concerns through one or more of the following channels:

Direct Line to Compliance Officer (currently the CFO)

Telephone and voicemail monitored by the Compliance Officer

Anonymous Reporting Option

Reports made anonymously will be taken seriously, but follow-up may be limited by lack of contact information.

Line Manager or HR Contact

Employees may also report concerns to their manager or an HR representative, who will escalate to the Compliance Officer.

Reports should include as much specific information as possible (dates, people involved, nature of concern, evidence).

Investigation Process

Upon receipt of a report:

a. The Compliance Officer logs the concern and assesses initial risk,

b. A formal investigation is launched, involving appropriate internal or external expertise,

c. Interviewing relevant parties and reviewing documentation,

d. Findings and recommended corrective actions are prepared, reviewed by senior management, and implemented where necessary.

Investigations are treated with confidentiality and professionalism.

Confidentiality and Protection

UPP will:

Maintain confidentiality to the extent feasible,

Protect reporters against retaliation, including unfair treatment, termination, or other adverse employment actions,

Take disciplinary action (up to dismissal) against anyone found to retaliate against a reporter.

Training and Awareness

UPP will provide:

Regular training for employees on how to raise concerns,

Communication of this policy to all current and new personnel,

Supplier awareness that ethical concerns should also be reported under this policy, especially those relating to labour and human rights risks.

Monitoring and Review

This policy shall be:

Reviewed at least annually by the Board and the Compliance Officer,

Updated as required to remain aligned with evolving regulatory requirements, SEDEX/SMETA expectations, and best practice.

Related Policies

This policy is part of UPP’s governance framework and complements:

Modern Slavery Policy

Corporate Social Responsibility Policy

Environmental Policy

Information Security Policy

Food Safety & Quality Policy

Confidential Reporting Policy

UPP is committed to adhere to the highest standards of ethical, moral and legal conduct of business operations. To maintain these standards, the Company encourages its employees who have concerns about suspected misconduct to come forward and express these concerns without fear of punishment or unfair treatment.

The Confidential Reporting Policy intends to cover serious concerns that could have grave impact on the operations and performance of the business of the Company. The policy neither releases employees from their duty of confidentiality in the course of their work, nor is it a route for taking up a grievance about a personal situation.

This policy outlines the Company’s Policy on Confidential Reporting and the procedure for investigating and dealing with all reported cases of illegal and unethical conduct and any other misconduct.

Specific objectives of the policy are:

1. To ensure all employees feel supported in speaking up in confidence and reporting matters they suspect may involve improper, unethical or inappropriate conduct within the Company;

2. To encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organisation

3. To provide clear procedures for reporting and handling such concern(s)

4. To proactively prevent and deter misconduct which could impact the financial performance and damage Company’s reputation

5. To provide assurance that all disclosures will be handled seriously, treated as confidential and managed without fear of reprisal of any form

6. To help promote and develop a culture of openness, accountability and integrity.

Reportable misconducts covered under this policy include:

1. All forms of financial malpractices or impropriety such as fraud, corruption, bribery, theft and concealment;

2. Failure to comply with legal obligations, statutes, and regulatory directives

3. Actions detrimental to Health and Safety or the work environment

4. Any form of criminal activity

5. Improper conduct or unethical behaviour that undermines universal and core ethical values such as integrity, respect, honesty, accountability and fairness.

The above listed reportable misconducts or concerns are not exhaustive. However, judgement and discretion is required to determine misconduct that should be reported under this policy.

Confidential Reporting Procedure

The Confidential Reporting Procedure involves steps that should be taken by the individual in reporting misconduct, and steps required for the investigation of the reported misconduct.

Step One - Raising concern(s) by the individual

The individual is expected to act in good faith and should refrain from making false accusations when reporting his/her concern(s), and also provide further evidence at his/her disposal to aid investigation of the issues reported.

The individual may raise concern through any of the following media (this can be done either by declaration or in confidence/anonymously):

Formal letter or anonymous note to the CFO or HR Manager

Declaration placed in the reporting box located in the main office and in the production area

Step Two - Investigation of Concerns and update on progress of investigation

All concerns are collected and reviewed monthly at Management’s Monthly Meetings.

If preliminary investigation conducted by Management Team shows that the concern falls within the Confidential Reporting Procedure reportable concerns, then further investigation shall be carried out.

Investigations should be handled promptly and as fairly as possible.

If the concern raised by the individual is frivolous or unwarranted, the Management Team shall ignore such concern, if necessary disciplinary measure in line with company employment policies shall apply to staff that raise concern out of malice.

The induvial has the right to protection from retaliation. But this does not extend to immunity for involvement in the matters that are the subject of the allegations and investigation.

Step Three - Report of Investigation and action on report

Upon conclusion of investigation, the representative of Management Team shall submit his/her report to the Human Resources.

Quarterly report to keep the management team abreast of developments in whistleblowing shall be submitted by representative of the Management Team.

All disciplinary action relating to the report shall follow the Company’s disciplinary procedures.