Whistleblowing Policy

1.1 Objectives of this policy
a. The Whistleblowing Policy (the ‘Policy’) of Expo City Dubai Authority and its subsidiary or affiliate companies (hereafter referred collectively as “Expo City”) is committed to a ‘Zero Tolerance’ approach to any malpractices or fraudulent act committed and requires its management and employees, to observe high standards of business and personal ethics in the conduct of their duties and responsibilities
b. The Expo City requires directors and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of Expo City must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations in the UAE
c. This document details the Whistleblowing guidelines established within Expo City
d. In this regard, a Whistleblower can be defined as any individual (Expo City employee and any third party), who has noticed or observed a malpractice or fraudulent activity and has resorted to using methods defined in this policy
e. Expo City strongly believes, that Whistleblowers will enable detection and handling of malpractice or fraudulent activity in an appropriate manner
f. The objectives of the Whistleblower Policy are to establish guidelines and procedures for:

• The submission of concerns regarding questionable matters by employees, directors, officers, and other stakeholders of Expo City, in a confidential and anonymous manner
• The receipt, retention, and treatment of complaints received by Expo City
• The protection of Whistleblower reporting concerns from retaliatory actions

1.2 Scope of this policy
a. This policy is applicable to all Expo City’s directors, employees (including seconded and outsourced employees) including any consultants or persons working with Expo City
b. This policy may also be used by any individual who is part of Expo City and would like to report a malpractice or fraudulent activity

1.3 Usage and control of this policy
a. Adherence to the provisions and requirements of this document is mandatory for all employees and consultants of Expo City
b. Access to the policy shall be restricted to “read only” for all users to prevent unauthorized modification
c. The Governance Department will be the custodian of the Whistleblowing Policy. To ensure that the policy referred to by any reader is the current version, the Policy shall be maintained in a central electronic repository on Expo City’s network. The exact location of the Policy shall be provided to all Departments/users by the Governance Department
d. The SVP - Portfolio Management Office is the owner of this policy
e. This policy has been approved by the Chief Executive Officer of Expo City, and any amendments to this policy will require approval from the Chief Executive Officer. Changes to the Forms and Templates defined in this policy shall be approved by the SVP - Portfolio Management Office

2.1 Violations reporting
a. A Whistleblower shall be encouraged to report information relating to illegal practices or violations of Expo City’s policies (a “Violation”) that Whistleblower in good faith has reasonable cause to believe is credible
b. Information shall be reported to SVP - Portfolio Management Office (SVP-PMO) or VP - Compliance
c. Anyone reporting a Violation must act in good faith, and have reasonable grounds for believing that the information shared in the report indicates that a Violation has occurred
d. Based on the nature of Expo City’s activities, the following are potential Violations that could be reported

i. A breach of professional conduct, unethical behavior by employees including any dishonest or fraudulent act or attempted act by employees of Expo City
ii. Not declaring a conflict of interest (e.g. a person using his position in Expo City to further his own interest or those of others);
iii. Disclosing confidential and proprietary information to third parties without authorization iv. Forgery or alteration of any Expo City official records including forging of signatures
v. Unauthorized alteration, addition or removal of information from Expo City’s manual records or Information systems
vi. Fraudulent financial reporting including manipulation of accounting data
vii. Misappropriation or misuse of funds, supplies, or other assets
viii. Impropriety in the handling or reporting of money or financial transactions
ix. Destruction, removal, or inappropriate use of official records, furniture, fixtures, equipment and assets
x. Financial malpractice (including false expense claims or misuse of valuables)
xi. Paying false (or inflated) invoices, either self-prepared or obtained through collusion with suppliers
xii. Providing undue privileges to suppliers, or granting business to favored suppliers, for kickbacks/favors
xiii. Accepting or seeking anything of material value from suppliers of Expo City
xiv. Offering, giving, accepting, agreeing, receiving or promising to pay something of value in order to gain commercial, contractual, regulatory or personal advantage
xv. Violation of any law or regulations
xvi. Willful override of established internal controls resulting in fraud xvii. Threat to staff health and safety
xviii. Incidents involving Harassment, victimization, bullying. violence or threatened violence, causing criminal damage
xix. Discrimination on grounds of gender, race, disability, or age
xx. Misuse of delegated powers or authority
xxi. Cover up in relation to any of the above matters
xxii. Any similar or related Violation

2.2 Authority of the Audit Committee
a. All reported Violations shall be forwarded to the Audit Committee by the SVP-PMO or VP-Compliance in line with Expo City Whistleblowing procedures
b. The Audit Committee shall be responsible for investigating, and making appropriate recommendations to the Chief Executive Officer (CEO), with respect to all reported Violations

2.3 Protection of the Whistleblower
a. This Policy is intended to encourage and enable Expo City employees, consultants, customers, licensees and suppliers to raise Violations within Expo City for investigation and appropriate action
b. Accordingly, no employees, consultants, customers, licensees and suppliers who, in good faith, reports a Violation shall be subject to retaliation or, in the case of an employee, adverse employment consequences
c. Moreover, an employee who retaliates against someone who has reported a Violation in good faith shall be subject to disciplinary actions as per Expo City disciplinary policies

2.4 Reporting channel
a. Expo City encourages employees to discuss the Violations with his/her Line Manager who shall report the same to the SVP-PMO or VP-Compliance. If the Whistleblower is not comfortable in reporting to his/her line manager, the Whistleblower shall report the matter directly to the SVP-PMO or VP-Compliance
b. Based on the merit of the complaint and in consultation with the CEO, the SVP-PMO or VP-Compliance shall escalate the complaint to the Audit Committee Chairman with a copy to the CEO
c. The Audit Committee shall in turn decide to commence investigations or otherwise
d. The Whistleblower shall report Violations through the following methods
i. Direct Meeting: The Whistleblower may opt to report a Violation to the SVP – PMO or VP-Compliance personally
ii. Phone Call: The Whistleblower may opt to report a Violation on 04 555 2424
iii. Email: Whistleblower discovering / encountering a Violation may opt to raise the concern by submitting an email to the email address Whistleblowing@expocitydubai.ae
e. Whistleblowers reporting a known or suspected Violation shall provide the following information:
i. Name, position and contact numbers of the Whistleblower if willing);
ii. Full name and position of the person(s) being complained about / reported;
iii. Details of the Violation;
iv. Relevant/material facts and reasonable grounds for the Violation; and
v. Evidence that supports the report (if any)

2.5 Investigation
a. Expo City is committed to investigating all Violations that are reported. Upon receipt of the claim of Violations, the SVP-PMO, may respond to the Whistleblower, setting out the general plan of action by the Management
b. All investigations will be conducted in a fair, independent and timely manner and all reasonable efforts will be made to preserve confidentiality during the investigation
c. Upon completion of the investigation, the Whistleblower may be informed of the results of the investigation as well as any corrective steps that are being taken

2.6 Anonymous complaints
a. Whistleblowers who opt to make an anonymous report due to fear or pressure especially for highly confidential and sensitive matters, may do so by detailing the suspected Violation in writing
b. Although, the investigators will try to exert all efforts to investigate on such complaints, proper investigations cannot be guaranteed since investigators cannot obtain further information from the Whistleblower and/or ascertain whether the report was made in good faith. Thus, it is preferable for Whistleblowers to reveal their identity to the SVP-PMO and measures will be taken to preserve confidentiality

2.7 Confidentiality
a. All Expo City employees have a duty of confidentiality. Any information received in the course of employment must not be disclosed to anyone outside of the Expo City and must not be used for an Employee’s own benefit or the benefit of others. However, whistleblowers are permitted to share relevant documents and evidence as part of the violation reporting process. They may be required to share additional, supporting documents and evidence as part of the investigation process
b. Any individual who reports or provides information as part of an investigation must maintain the confidentiality of that information, and of the investigation. Further, all information reported to the SVP-PMO and Audit Committee, irrespective of how it is received, must be considered confidential, and may not be disclosed or discussed with any other individual, other than for the purpose of conducting the investigation c. The SVP-PMO and Audit Committee will manage all reports in the strictest confidence to protect the rights of any party subjected under investigation

2.8 Malicious allegations
a. Whistleblowers are discouraged from making false, frivolous,or malicious allegations. Any malicious use of the Whistleblowing policy by Expo City Employees will result in disciplinary action against the Whistleblower, up to and including termination of employment