Whistleblowing Policy

SICO is committed to the highest standards of good governance, openness, transparency, integrity and accountability. Consequently if any Staff Member has well-founded concerns, they have a duty to SICO and their colleagues to speak up and report the situation immediately to their Department Head in good faith so that the matter can be promptly investigated.

These concerns may include any of the following:

• Staff think that they or anyone else at SICO may have violated any applicable law, regulation, or the Code of Conduct
• Staff are aware of any fraud (either attempted or realized)
• Concerns about the integrity of individual colleagues
• Staff detect a deficiency in SICO's processes or controls that would allow violations to go undetected
• Concerns about health and safety risks, including risks to the public/employees and damage to environment
• Indulgence in corruption, unauthorized use of Bank funds/property/resources for illegal, improper, or unethical purposes

The Department Head must then report such notifications to the Head of Internal Audit as soon as reasonably practicable. If the issues or concerns relate to the Department Head, the staff member should contact the Head of Internal Audit directly. If the situation relates to the Head of Internal Audit then the staff member should raise the issue with the Chief Executive Officer. Additionally, if the disclosures are not investigated, this should be raised as an issue with the Chief Executive Officer.

All such communications shall be treated with confidentiality to the greatest extent possible; this rule is intended to make it easier for staff members to report irregularities in good faith, without fearing that their actions may have adverse consequences.

"Good faith" means unequivocal belief in the veracity of the reported incidents. However, if any staff member deliberately makes false allegations or makes a report maliciously, such he/she shall not be protected. This behavior will be regarded as extremely serious and may result in disciplinary action including dismissal.

Staff members will be required annually to provide an affirmation that they have read the whistleblowing procedures outlined in the staff code of conduct and understand their duty to report immediately any concerns for investigation and action. Staff must also confirm that they have not come across any situation that warrants reporting under this clause.