Whistleblower policy

1. Introduction

This policy (the "Policy") establishes the fundamental principles and operational framework through which World Food Trading Group ("WFTG" or the "Company") will receive, evaluate, and investigate reports of alleged irregularities, omissions, or offenses brought to the attention of its employees, customers, suppliers, or other stakeholders.

This Policy serves as a vital mechanism for upholding the integrity, internal governance, and reputation of WFTG. It aids in the identification of potential risks and the implementation of appropriate corrective actions. This includes, but is not limited to, the early detection of instances of fraud or other serious misconduct, the application of suitable measures to responsible parties, and, when necessary, notification to the relevant Authorities.

WFTG is committed to fostering an environment of trust and safety for its employees, customers, and suppliers. The Company encourages the good faith reporting of illegal acts or serious offenses that come to their attention.

This Policy does not diminish any rights afforded to a reporting person under applicable laws and should not be interpreted as conflicting with existing laws, regulations, and associated rights. Furthermore, this Policy is not intended to, and shall not be deemed to, prohibit or restrict a reporting person in any manner from communicating directly with, cooperating with, or responding to any inquiry from investigatory or other agencies, authorities, or bodies, including foreign regulatory or investigatory agencies, regarding any potential violation or suspected wrongdoing.

2. Regulatory Framework

This Policy is designed to comply with the requirements of applicable legal and regulatory frameworks relevant to World Food Trading Group's operations.

3. Scope of the Policy

A. Definitions

For the purposes of this Policy, the following definitions shall apply:

Breach: An unlawful act or omission that relates to the laws and regulations applicable to WFTG, as outlined below.
Report: The oral or written communication of an actual or potential Breach or a concern.
Reporting Person or Whistleblower: The natural person who reports or discloses information on Breaches in the context of their work-related activities with WFTG.
Reported Person: The individual against whom an allegation has been made, or a natural or legal person who is referred to in the Report as someone to whom the irregularity is attributed or with whom that person is associated.
Retaliation: Any direct or indirect act or omission that occurs in a work-related context, prompted by Reporting, which causes or may cause unjustified detriment to the Whistleblower. Retaliatory actions may include, but are not limited to, harassment, discriminatory treatment, unfair performance evaluations, salary actions (freeze or adjustment), changes in work assignments, demotion, termination of employment, or the withholding of an entitlement.
Responsible Personnel: An impartial person or department within WFTG designated to assess the information provided by the Reporting Person in the Report (see Section 6 below).
B. Reporting Persons
This Policy applies to the following categories of Reporting Persons:
a. All employees of World Food Trading Group. b. Contractors, subcontractors, and suppliers of WFTG, as well as individuals working under their supervision. c. Shareholders and members of the Board of Directors of WFTG. d. Persons whose work-based relationship with WFTG has ended or is yet to begin, for information on Breaches acquired during the recruitment process, pre-contractual information, or information acquired during the course of their employment.
This Policy also extends to colleagues and relatives of Reporting Persons, as well as to legal entities that the Reporting Persons own, work for, or are otherwise connected with in a work-related context.

C. Breaches

WFTG encourages and considers it critical for Reporting Persons to provide information regarding offenses and suspected illegal behavior, incidents of mismanagement, or serious irregularities or

omissions related to WFTG's regulations, policies, procedures, financial reporting and financial statements, whenever the Reporting Person reasonably believes that the information disclosed is substantially true.

Reporting Persons are encouraged to report in good faith any Breaches or suspected Breaches of applicable laws and regulations, such as:

Acts or omissions involving gross negligence, potential fraud, or corruption.
Breach of laws and regulations regarding the prevention of money laundering and terrorist financing.
Acts or omissions conflicting with the interests of WFTG involving serious violations of WFTG's policies and procedures.
Acts or omissions that endanger the health or safety of an employee.
All forms of harassment (e.g., sexual, racial, religious, gender identity, etc.), as well as abuse of power.
Offering or accepting a bribe by a WFTG employee.
Expropriation, theft, or mismanagement of assets and money belonging to WFTG or its customers.
Breach of confidentiality and data protection laws.
Issues related to product safety and quality within the food trading industry.
Unfair competition or anti-trust violations.
Violations of import/export regulations and customs laws.
Acts or omissions relevant to the integrity and accuracy of WFTG's financial statements and reporting.
Acts harmful to the environment.

Any other illegal or unethical conduct that could significantly impact WFTG.

Information on Breaches includes any information and reasonable suspicions about actual or potential Breaches that have occurred or are very likely to occur within WFTG and about attempts to conceal such Breaches.

Reporting Persons are strongly encouraged to submit substantiated information on Breaches, enabling WFTG to reasonably undertake actions to investigate and follow up on the information provided.

D. Local Regulations

In jurisdictions where local laws or regulations establish stricter requirements than those outlined in this Policy, the stricter requirements shall take precedence.

4. Anonymity and Confidentiality

WFTG has established a secure process to ensure the anonymity of any Reporting Person, as well as the confidentiality of their identity and that of any third party mentioned in the Report.

Whistleblowers shall be protected against any form of Retaliation or reprisal actions based on the following principles:

The identity of the Whistleblower, should they choose not to remain anonymous, will be protected, and confidentiality will be maintained.
Submitted Reports will be accessible only to specifically designated individuals whose number is limited to those responsible for conducting the investigation and who are obligated to act with discretion and confidentiality. Adherence to these principles will also contribute to protecting the identity of Reported Persons.
WFTG will ensure that Whistleblowers are adequately protected against potential adverse consequences, such as threats, attempts at Retaliation, discrimination, or any other form of unfair treatment.

Disclosure of the Whistleblower's identity may be required by a judicial or other legal procedure in the context of investigating the reported case. In such instances, the Whistleblower will be informed before their identity is disclosed, unless such notification would jeopardize the related investigations or judicial proceedings. When informing the Whistleblower, WFTG will provide an explanation for sharing the confidential data.

WFTG ensures that Reported Persons are fully protected against potential negative impacts in cases where the assessment of the Report does not reveal a Breach of this Policy. Even when an investigation confirms a justified violation and measures are taken against the Reported Persons, their protection against unintended negative effects is ensured, irrespective of potential sanctions imposed by competent bodies.

WFTG will implement all necessary technical and organizational measures to safeguard personal data. Any processing of personal data under this Policy will be conducted in accordance with relevant national and European data protection regulations. The personal data of involved parties will be protected and processed solely for the purpose of verifying the validity of the Report. The [Specify Department, e.g., Legal Department] will maintain an electronic file containing all submitted Reports, along with associated documentation. These records will not be stored for longer than necessary and will be deleted in accordance with applicable laws and regulations.

5. Procedure

A. Reporting Channels

Reports can be submitted via the following channels:

Email: [Insert dedicated confidential whistleblower email address, e.g., [email address removed]]
Postal Mail: [Insert physical mailing address, ensuring it reaches the Responsible Personnel discreetly, e.g., Confidential Reporting Line, World Food Trading Group, [Address]]
In-Person Meeting: Upon the request of the Whistleblower, a Report may also be submitted through a physical meeting with the Responsible Personnel. In such cases, with the Whistleblower's consent, the conversation will be recorded in a durable and retrievable format.

To facilitate the proper examination and assessment of submitted Reports, Reporting Persons are encouraged to provide all available relevant information, including the facts giving rise to the suspicion or concern related to the Report, indicating the date and nature of the event, the name(s) of the person(s) involved, as well as any potential witnesses or other evidence, such as documents and locations.

B. Processing of Reports

WFTG's Responsible Personnel will process reported Breaches in the following manner:

Upon receipt of a Report, the Responsible Personnel will undertake an initial assessment of the information provided by the Reporting Person. All individuals assigned to the examination or assessment of a specific case are required to disclose any conflicts of interest to WFTG prior to taking any action related to the case and must refrain from any further involvement in that case.
The Responsible Personnel will follow up on all Reports, and an acknowledgement of receipt will be provided to the Reporting Person within seven (7) days of submission.
If the case falls outside the scope of this Policy, is clearly unsubstantiated, or if no investigation can be reasonably undertaken, the Report will be closed and archived. The Reporting Person will be notified of this decision via [Specify communication method, e.g., email], if their contact information is available.
If the case warrants investigation, the Responsible Personnel will initiate an internal investigation. This may involve engaging other relevant functions within WFTG based on the nature of the allegations and the specific areas of the business involved. Additional information may be requested from the Reporting Person if necessary. The Reported Person may also be asked to provide relevant information during the investigation.
Based on the findings of the investigation, the Responsible Personnel will determine appropriate remedial actions and inform the Whistleblower of the decision taken regarding their Report. If the reported Breach is deemed material, the Board of Directors of WFTG may be informed of the Breach and the outcome of the investigation.
In all cases where contact information is available, WFTG will provide feedback to the Reporting Person within a reasonable timeframe, not exceeding three (3) months from the acknowledgement of receipt. Such feedback may include, but is not limited to: Referral to other appropriate channels or procedures in cases where Reports exclusively affect the individual rights of the Reporting Person.
Closure of the procedure due to a lack of sufficient evidence or other justifiable grounds.
Confirmation of the launch of an internal inquiry and, where appropriate, a summary of its findings and any measures taken to address the issue raised.
Referral of the matter to a competent external authority for further investigation, in accordance with applicable laws.

C. External Reporting

This Policy does not prevent the reporting of Breaches or relevant information to external channels maintained by competent authorities, in accordance with applicable laws. Any reporting undertaken in accordance with this Policy does not constitute a prerequisite for submitting reports to external channels maintained by competent authorities.

6. Responsible Personnel

WFTG will ensure that the designated Responsible Personnel possess the necessary professional skills, knowledge, and impartiality to assess and investigate reportable Breaches in accordance with WFTG's policies and the applicable legal framework. Designated Responsible Personnel have a duty to maintain professional secrecy and confidentiality when handling and transmitting information both within WFTG and externally to any competent or judicial authority.

The Responsible Personnel may be designated from the [Specify Department, e.g., Legal Department, Compliance Department, or a dedicated Whistleblowing Committee]. Depending on the nature and complexity of the reported Breach, and if the investigation requires specialized knowledge or skills, the Responsible Personnel may, considering the specifics of the case, also involve other qualified members of WFTG's staff (e.g., staff members from Human Resources, Finance, Operations, or Quality Assurance).

In any event, any identified conflicts of interest that have not been disclosed or any breach of confidentiality by involved staff members will be considered a serious violation of professional conduct by the Responsible Personnel and will be subject to appropriate disciplinary measures.

7. Review

This Policy will be reviewed at least once annually or whenever significant regulatory changes occur that necessitate updates.