Whistleblowing Management Policy

1. Purpose & Scope

The purpose of this Whistleblowing Management Policy is to establish a safe and reliable framework for reporting concerns related to misconduct, breaches of company policy, unethical behaviour, or violations of legal and regulatory requirements.

The Policy aims to protect the interests of Raysut Cement Company (RCC) SAOG, its employees, stakeholders, and the wider community by ensuring that all whistleblowing disclosures are treated seriously, investigated thoroughly, and resolved appropriately.

This Policy applies to all board members, officers, employees, contractors, suppliers, vendors, and other external stakeholders to the extent permitted by applicable laws and relevant contractual arrangements with the Company.

It encompasses reports of suspected wrongdoing occurring within the Company’s operations, as well as any actions that may adversely affect RCC’s reputation, assets, or stakeholders.

By defining clear procedures and protections, the Policy ensures that everyone is able to raise concerns without fear of retaliation, discrimination, or harassment.

2. The Policy Statement

1. Raysut Cement Company (RCC) is committed to the highest standards of integrity, ethical conduct, accountability, and good corporate governance. RCC encourages a culture where employees, contractors, suppliers, and other stakeholders feel safe and confident to raise concerns about wrongdoing without fear of retaliation.
2. This Whistleblowing Policy provides a confidential, secure, and transparent mechanism for reporting any suspected misconduct, violation of laws or regulations, breach of RCC policies, unethical behaviour, or any activity that may harm the Company, its employees, shareholders, or stakeholders.
3. RCC strictly prohibits any form of retaliation, discrimination, harassment, or adverse action against any individual who reports concerns in good faith. All reports will be handled with utmost confidentiality, impartiality, and professionalism. RCC is committed to ensuring that every disclosure is assessed promptly, investigated fairly, and appropriately resolved.
4. The Internal Audit Department is responsible for overseeing the Whistleblowing Policy, including receiving concerns/issues, initiating/ conducting or supervising investigations, maintaining records, and preparing final investigation reports. Management is responsible for taking corrective or disciplinary actions based on the investigation outcomes.
5. This Policy reflects RCC’s dedication to transparency, accountability, and the continuous strengthening of its governance and compliance frameworks. All employees and stakeholders are expected to cooperate fully with this Policy.
6. This Policy is implemented in accordance with the applicable laws and regulations of the Sultanate of Oman. Where relevant, the Company will ensure alignment with labour, criminal, data protection, anti-money laundering, and corporate governance requirements in force from time to time.
7. This Policy shall be made publicly available on the RCC website to ensure transparency and to provide accessible reporting channels for employees, contractors, suppliers, and external stakeholders.

3. Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and other stakeholders to raise serious concerns internally so that the Company can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees, contractors, vendors, and volunteers to report concerns about violations of the Company’s code of ethics or suspected violations of laws or regulations that govern the Company’s operations.

4. No Retaliation 

It is contrary to the ethics of the Company for anyone to retaliate against any employee, or other stakeholders who, in good faith, report an ethics violation, or a suspected violation of law, such as a complaint of discrimination, suspected fraud, or suspected violation of any regulation governing the operations of the Company. Anyone who retaliates against someone who has reported a violation in good faith shall be subject to disciplinary action, which may result in punitive measures pursuant to the relevant laws and regulations.

5. Whistleblower Protection Measures

Whistleblower protection under this Policy is intended to prevent retaliation for reporting concerns in good faith. It does not limit the Company’s ability to take lawful and fair employment actions for reasons unrelated to the disclosure, provided such actions are based on objective grounds and are not retaliatory in nature.

The following measures may be applied, case by case, for the protection of the whistleblower;

• Protection from dismissal, demotion, transfer, or salary reductions.
• Protection from threats, harassment, and bullying.
• Protection of identity.
• Option to request temporary work environment changes.
• Protection even if the report is not proven, if it was made in good faith.

6. Reporting Channels

RCC provides multiple secure and confidential channels for reporting concerns, accessible to all employees, contractors, and external stakeholders. These channels ensure timely receipt, protection of information, and direct access to Internal Audit.

Reports may be submitted through the following channels:

1. RCC Website: Whistleblowing Form  Link  
2. Email:  whistleblower@raysutcement.com.om
3. Dedicated Phone Line: +968 24903319
4. Mobile Hotline: +968 91992502
5. Direct face-to-face disclosure to any employee of the Internal Audit Department

7. Requirements for Submitting Reports

Reports should include sufficient information and evidence to enable a proper investigation. This is particularly important for anonymous reports, where the Investigator may not be able to obtain additional clarification from the Reporter.

To the extent possible, Incident reports should include the following:

1. The date(s) of the Incident(s).
2. The identity of individuals and any witnesses involved.
3. A description of the specific actions or omissions that constitute the Incident.
4. An explanation of how the Reporter became aware of the Incident.
5. Any steps taken by the Reporter to date in relation to the Incident; and
6. Any materials, documents, or evidence relevant to support the report.

8. Anonymous Reporting

The Company fully supports anonymous reporting and does not require reporters to disclose their identity. Anonymous reports will be handled with the same care, confidentiality, and seriousness as named reports.

The Company will not seek to identify anonymous reporters, except where disclosure may be required by applicable law, regulatory authorities, or a court order.

9. Acting in Good Faith

Individuals submitting a complaint under this Policy are expected to act in good faith and provide information that they believe to be true at the time of reporting. RCC recognizes that a Reporter may not have complete evidence; however, reports must never be made with malicious intent, reckless disregard for the truth, or with the purpose of causing harm.

Any complaint found to be intentionally false, fabricated, or made with malicious intent may be treated as a serious disciplinary offence, subject to appropriate action under RCC’s disciplinary framework. This provision is not intended to discourage genuine reports made in good faith, even if the investigation does not substantiate the concern.

10. Confidentiality

Any incident reported pursuant to this Policy shall be kept confidential and shall only be disclosed on a need-to-know basis, consistent with the need to conduct the investigation and to reach the required decision.

RCC prohibits any unauthorized disclosure or attempt to identify an anonymous Reporter. Any breach of confidentiality may result in disciplinary action.

11. Personal Data Protection

All personal data collected or processed under this Policy shall be handled with appropriate care and confidentiality. The Company will process such data in a secure manner and in line with applicable personal data protection requirements, ensuring that access is limited to authorized persons and retained only for legitimate purposes.

12. Issues that may be raised pursuant to this Policy

1. Any discrimination against an employee, whether on account of religion, race, caste, gender, or abuse of a colleague.
2. Any incident involving fraud, theft, embezzlement, bribery, conflict of interest, or any suspicion thereof.
3. Any suspicion of bullying, intimidation, or harassment against an employee.
4. Any abuse of authority or violation of internal policies and procedures, and any assistance in collusion thereof.
5. Any fraudulent financial reporting- earnings management, overstatement of assets, understatement of liabilities, including false representation of any performance indicators.
6. Any action that would compromise the integrity of the Company’s data, records, systems, and/or confidential information.
7. Divulging information relating to dealings between the Company and third parties, such as customers, contractors, agents, and authorities.
8. Any acts which will be prejudicial or affect the interests of the Company.
9. Any action which may negatively affect the reputation of or defame the Company.
10. Any unsafe practices, breach of HSSE rules, environmental harm, concealment of incidents, or failure to comply with legal / HSSE requirements.
11. Any violation of laws, regulations, licenses, permits, or reporting obligations applicable to the Company.
12. Any retaliation, threat, adverse treatment, or attempted retaliation against a person who has raised a concern in good faith.

13. Issues that may not be raised pursuant to this Policy 

1. Personal grievances with other employees.
2. Disputes or disagreements between employees that are personal in nature.
3. Concerns regarding interpersonal conflicts or communication issues with colleagues.
4. Complaints about management style or supervisory approach not involving policy breaches.
5. Grievances related to the allocation of work or the perceived unfair distribution of tasks.
6. Issues with working conditions that do not breach laws or company policies.
7. Concerns over performance appraisals or feedback received from managers.
8. Complaints about salary, pay, or benefits that do not involve a breach of law or company policy.
9. Disagreements over holiday or leave approvals, unless breach of law or policy.
10. Non-policy related concerns about working hours or shift patterns.

14. Escalation of Criminal Matters

Where an investigation identifies matters that may constitute a criminal offence, the Company may refer such matters to the appropriate authorities in accordance with applicable legal and regulatory obligations.

These provisions are intended to support transparency, fairness, and accountability, while ensuring the Policy is implemented in a practical and legally sound manner.