Introduction

   Kuwait Resorts Company K.S.C.P. is committed to (hereinafter referred to as the “Company”) adheres to the highest standards of transparency, integrity and responsibility. The company has prepared a whistleblowing policy that specifies the procedures and guiding principles for reporting any suspicious behavior or any violating behavior that occurs within the company so that the necessary corrective action can be taken in a timely manner. This policy reflects the company's commitment to standards of professional and ethical behavior by helping to create an environment that enables company employees, members of executive management, the Board of Directors, and key stakeholders to express any concerns or inappropriate behavior while ensuring the protection of the reporting person.

 

-This policy forms an integral part of the company's governance framework.

 

-This policy was developed taking into account the corporate governance rules issued by the Capital Markets Authority, in addition to other regulatory requirements, and leading international practices in this regard.

 

-In the event of a conflict between this policy and prevailing laws and regulations, the latter shall prevail.

 

Purpose

This whistleblowing policy addresses the company's commitment to integrity and ethical behavior by helping to provide an environment in which employees and other key stakeholders can report internal and external whistleblowers “in good faith” regarding activities that are illegal, unethical, inappropriate or otherwise unlawful. of mismanagement without fear of any punishment or arbitrary action. Therefore, this policy establishes clear guidelines and procedures for reporting any violations by company employees and other key stakeholders. It also allows concerns to be reported by board members, former employees, consultants, suppliers, contractors and any other party with whom the company has a business relationship.

 

This policy is an integral part of the company's approved Business Conduct Charter.

 

References

This policy has been prepared in accordance with the Governance Rules, Book Fifteen, issued by the Capital Markets Authority:

 

•For the sixth rule, which is concerned with promoting professional behavior and ethical values.

 

•The ninth rule is to recognize the role of stakeholders.

 

Scope of application

•This policy applies to the process of reporting all types of wrong, illegal, or unethical violations and behaviors that violate the law and legislation, or those practices that violate the company’s policies, values, and principles. The policy applies to all members of the Board of Directors and/or current employees and/or former employees and /or consultants, and/or suppliers, customers, and/or any other parties with whom the company has a business relationship or common interests, without distinguishing between any of them, and this policy is considered a continuation of the laws and legislation issued by the relevant regulatory authorities without replacing them.

 

•This policy applies to all actions, transactions or contracts, whether those actions take place at the company’s headquarters or outside it, and regardless of the geographical scope of the violation, which may affect the company’s reputation, affect its performance, or expose it to accountability by others.

 

•The time frame for reporting violations includes reporting any violation, whether it occurred in the past, current violations, or violations likely to occur in the future as a result of wrong or illegal practices or procedures.

 

Responsibility for implementing the policy

The “Secretary of the Board of Directors” and “all parties concerned with receiving reports” are responsible for ensuring that all company employees and key stakeholders are able to report any concerns or suspicious activities without fear of any arbitrary measures being implemented against them. All employees and stakeholders also take The chief departments shall provide the necessary procedures for reporting any violation or misconduct that comes to their attention as soon as possible. Any inquiries about the content or scope of application of this policy should be directed to the Secretary of the Council and all parties concerned with receiving reports in the company to provide advice. The Chairman of the Board of Directors is responsible for forming an investigation committee to follow up on the results of investigations conducted into any reports received.

 

Training programs are being prepared to raise the level of awareness among all company employees and key stakeholders regarding this policy through coordination between the Internal Audit Department and the Human Resources Department. These programs include providing practical advice necessary to avoid suspicious behavior while emphasizing the importance of This policy and the company’s approved Code of Business Conduct.

 

Definitions

 

Reporter: For purposes of this policy, the term “reporter” means a person who reports suspicious behavior or activity to relevant company authorities who have the authority or actual ability to take necessary corrective action.

 

Reported person: The reported person means the person against whom the report is being made and whom the informant may believe is engaging in any suspicious behavior.

 

Acting in good faith: All cases of reporting must be done based on the good faith of the informant and based on sufficient reasons that justify the extent of the need for reporting. Any report that later becomes clear that it was made with the knowledge that the information that was provided was false with the aim of causing harm to the person reported will be dealt with in a manner Serious behavior may lead to taking appropriate disciplinary measures in accordance with the company’s approved sanctions list, which may sometimes lead to termination of service.

 

Protected disclosure: Protected disclosure is any disclosure of suspicious behavior or activity that requires support and protection of the reporting person from any action that may be taken against him as a result of that disclosure. Disclosure is considered protected disclosure only when it is made in a framework of good faith and is related to conduct. Questionable.

 

Questionable behavior: Questionable behavior includes any behavior that is illegal, unacceptable, or undesirable, and includes:

 

-Intentional falsification, concealment, disposal, or use of documents for work purposes or illegal exploitation of information or job position.

 

- Submitting or publishing financial records or data that are incorrect or misleading in any way and intentionally.

 

Dishonest Behavior

Dishonest behavior includes:

 

-Dishonest behavior by holders of influential positions, including accepting or granting bribes, transactions carried out secretly, manipulating election results, transferring or laundering money, defrauding shareholders, etc.

 

-The employee behaved dishonestly, deliberately failed to perform the job duties assigned to him, or exploited his position to obtain personal interests for himself, the company, or any external party, or caused the external party to bear losses.

 

Negative behavior

Negative behavior includes:

 

-Unethical behavior or misconduct is any other behavior that violates the company’s values, policies, or the company’s Code of Business Conduct.

 

-Any inappropriate behavior that would harm the company’s interests or cause the company to incur financial or non-financial losses (including committing acts of harassment and unsafe, inappropriate, hostile, or insulting practices at the work site).

 

Questionable accounting or auditing procedures

This includes accounting or auditing procedures that:

 

-It is technically sound but is not consistent with the intent or spirit of the law.

 

-Not consistent with accounting standards.

 

-Involves inappropriate or questionable interpretations of accounting or auditing standards.

 

-Involves fraud or fraudulent acts in nature but:

 

-The employee did not do it with the aim of making a profit or causing a loss.

-It was done on the employee’s belief that it might bring benefits to the company.

 

Punitive Measures

Punitive measures mean any arbitrary measures that the company may take against the reporting person as a result of submitting a report in accordance with this policy. Punitive measures include, but are not limited to:

 

· Dismissal, withdrawal of promotion, or lowering of job grade.

 

· Any form of discipline or intimidation.

 

· Discrimination or bias.

 

· Any action that results in injury or loss.

 

· Threatening to take disciplinary measures (explicit or implicit, conditional or unconditional) or actually taking disciplinary measures unlawfully.

 

Reporting cases

 

Reporting must be made immediately in accordance with the procedures of this policy in any of the following cases, but not limited to:

 

- Fraud or intentional error during the process of preparing, evaluating, reviewing or auditing any company financial statements.

 

-Fraud or intentional error when registering or keeping the company’s financial records.

 

- Deficiencies in the company’s internal controls or non-compliance with them.

 

- Misleading or providing false data to or by any company official regarding any item in the company’s financial statements, financial reports, or audit reports.

 

-Failure to report the company’s financial position as required by applicable laws and regulations.

 

-Misappropriation of the Company's assets and/or income through mismanagement including but not limited to criminal acts, fraud, forgery, willful negligence, withholding of financial or non-financial information, or bribery.

 

-Exploiting influence to obtain private or personal benefit.

 

-money laundering.

 

-Cheating and forgery.

 

-Misusing inside information for personal gain.

 

-Intentionally violating laws and regulations.

 

-Intentionally violating the company’s policies and procedures, causing harm to the company or stakeholders.

 

-Practices that harm the work environment or pose a threat to the company’s employees, customers, stakeholders, company assets, society, or the environment.

 

-Wrong ethical practices and behaviors that violate public order and morals that may affect the reputation of the company or its employees.

 

The cases that are reported are cases that may result in the company violating laws and regulatory instructions, or may result in material damage or financial loss to the company, or may negatively affect the company’s reputation. Otherwise, complaints that do not have an impact on the company’s reputation and do not result in financial loss or violation of laws. If complaints are received regarding employee affairs or job benefits and salaries, they are directed to the Personnel Affairs Department.

 

Protection of the reporting person

 

The Company protects the whistleblower against any unfair decision to terminate the service/relationship or any harmful practices made against the employee unfairly or arbitrarily, and no arbitrary decision will be taken or recommended against any person who reports any suspicious behavior in good faith.

 

If the employee believes that an arbitrary decision has been taken against him as a result of reporting any suspicious behavior, he can notify the Secretary of the Board of Directors or send a message to the e-mail designated for that purpose, who in turn will notify the Chairman of the Board of Directors immediately upon receiving the information from the employee.

 

Notwithstanding the above, this policy does not protect the whistleblower or the employee from taking any disciplinary action against him if that decision is taken as a result of other behavior by the whistleblower that differs from the questionable behavior that the whistleblower disclosed.

 

The Company will not tolerate harassment or harm caused to a bona fide whistleblower for reporting suspicious behavior or activity.

 

The reporting person must have good faith and have reasonable grounds to believe that the information disclosed constitutes suspicious behavior or activity. If it is proven that the reports submitted are unconfirmed or incorrect, or malicious complaints were submitted intentionally, the company will deal with them seriously and take appropriate disciplinary measures, which may lead to dismissal from work in accordance with the relevant laws and in accordance with the provisions of the Labor Law, company policies and the sanctions list. applicable in the company.

 

Every person reporting a violation is obligated to do the following:

- Ensure credibility in the report, by avoiding rumors and fears that are not based on practical reality.

 

- Commitment to objectivity, ensuring accuracy in reporting, and staying away from personal disputes, or exploiting or employing reporting to achieve personal gain, or to undermine confidence in the company’s employees and officials.

 

- Accuracy in conveying the news, clarity in the language of reporting, avoiding incomprehensible symbols or signs, or incomplete or fragmented information, and clarifying all the details related to the report, which would guide the case, description, and location of the violation, and attaching anything that would give details and evidence of the violation. As much as possible and consistent with the nature of the violation.

 

-Report the violation immediately.

 

-Accept the terms and conditions for reporting violations contained in this policy.

 

-The whistleblower will be held accountable as a result of false, incorrect, or malicious allegations, which may lead to tarnishing the reputation of the company or one of its employees, which may include taking disciplinary measures against the whistleblower if the report is proven malicious or false and causes harm to others, or suing him before judicial authorities.

 

The reporter must adhere to complete confidentiality of the report in order to help the company in exercising its duties regarding the report, conduct the necessary research and investigation in accordance with its established procedures, and preserve the reputation of the company or others from allegations that are not based on sufficient evidence, which - if they are not serious or are found to be false or untrue - would It creates a right for the company or a third party to prosecute him.

Anonymous reports

 

This policy encourages the company's employees and key stakeholders to identify themselves when submitting any report whenever possible, and the company respects their desire to remain anonymous when submitting a report. It should be noted that anonymous reports have less impact and are considered at the company's discretion, taking into account the following factors:

 

-The seriousness and credibility of the submitted report.

-The possibility of confirming the report from reliable sources.