​Whistleblowing  Policy

1. Introduction

Oman LNG is committed to the highest possible standards in terms of governance practices, openness/transparency, honesty, accountability, professionalism and duty of care in delivering ones responsibilities as prescribed in OLNG's "Statement of General Business Principles" and "Code of Conduct".

2. Purpose

This Policy aims to encourage every individual working for or dealing with the Company to report any Unethical Practices at any level of the organizational structure with complete comfort, confidence and protection.

Also, it aims to define and establish the position of the Company on the framework for reporting Unethical Practices, and establish suitable steps to investigate and take necessary corrective actions.

3. Definition

a. "Unethical Practice" means any behavior or practice of the Company, its employees, contractors, suppliers or their individual employees in relation to their business dealings with the Company which is believed to be inconsistent with the Company's General Business Principles and its general spirit, and includes, but is not limited to, the following suspected activities / improper practices:

  • - Fraud or fraudulent financial reporting;
  • - Manipulation of Company data / records, including forging official documents;
  • - Abuse of authority at any defined level in the Company;
  • - Disclosure of confidential / proprietary information to unauthorized personnel;
  • - Knowingly violating applicable laws and regulations, thereby exposing the Company to penalties, fines or any legal action;
  • - Any instances of misappropriation or abuse of Company property/assets;
  • - Actively violating any laid down Company policy, including the Code of Conduct;
  • - Economically wasteful act or action;
  • - Criminal activity;
  • - Harassment of any nature to employees or any other third party.
  • - Using confidential information acquired in the course of one's work for personal advantage;
  • - Any other activities whether unethical or improper in nature and damaging the interests of the Company;
  • - Attempts to conceal any of the above.

b. "Whistleblower" means any person (employee, director, customer, vendor or any other individual stakeholder) reporting an Unethical Practice under this policy.

4.  Reporting Unethical Practice

a. The Company has introduced this policy to enable you to raise your concerns about Unethical Practices at an early stage and in the right way. If something is troubling you which you think the Company's management or Board should know about or look into, then please refer to this policy.

b. Normally, concerns should be raised with the appropriate department that the issue is dealt with within the Company and should be handled in line with company policies and procedures. It is recognized, however, that there may be occasions where the use of normal chain of command may not be appropriate. Persons may believe their concerns:

  1. are overly sensitive;
  2. would  not be receiving appropriate attention;
  3. are of particular significance;
  4. the line manager/department is the perpetrator of the issue to be addressed or
  5. the person may be sufficiently uncomfortable such that it warrants the use of another confidential reporting channel.

    Hence, the Whistleblower may report such Unethical Practice in writing to WhistleBlow@omanlng.co.om. This mailbox is regularly reviewed by the Chief Internal Auditor at the Company. 

c. The Chief Internal Auditor shall never reveal the name of the Whistleblower without his/her consent unless required by law. If they at some point of time are ordered and required by law to report the name of the Whistleblower, they shall inform the Whistleblower, unless they have lawful reasons not to do so.
Where the Whistleblower feels very exposed and is afraid of being victimized (s)he can e-mail anonymously when reporting the issue by hiding his / her identity. In this respect the Whistleblower shall provide and deliver all related information and facts with the initial report to facilitate the investigation process. The Whistleblower can remain anonymous in follow-up communications and clarifications by providing a discreet e-mail address.

d.The Whistleblower must address the following aspects, while reporting any issues under this policy:

  1. Clear understanding of the issue being raised.
  2. The issue should not be merely speculative in nature but should be based on actual facts.
  3. Should contain as much specific information as possible to allow  proper  inquiry/ investigation.
  4. If the Whistleblower has a personal interest in the matter, (s)he will be required to disclose this.

5. Protection to Whistleblower

  1. The identity of the Whistleblower shall be kept confidential at all times, unless otherwise agreed with the Whistleblower or required by law (e.g. during the course of any legal proceedings, where the Whistleblower is required to give evidence in court).

     
  2. No unfair treatment shall be vetted out towards any Whistleblower acting in good faith by virtue of his/her having reported issues under this policy and the Company shall ensure that full protection is granted to him/her against any action.