TSODILO RESOURCES LIMITED WHISTLEBLOWER AND GREIVANCE PROCEDURE
SpeakOut is the brand name for Tsodilo Resources Ltd. and its operating subsidiaries' (herein after known as "Tsodilo") grievance and whistleblowing program. This program is operated internally by Tsodilo and serves as a mechanism for employees to voice their concerns and grievances to the management of the company without fear of retaliation.
When a person submits a report, the Corporate Governance Committee will protect the identity of the person making the report and will not require the caller's name
Who can submit a report to SpeakOut
Any person in the world, including employees, stakeholders*, service providers and suppliers, who has important information about unethical practice in Tsodilo or its subsidiaries is welcome to make use of any of the SpeakOut program.
The Chairman of the Corporate Governance Committee is an independent director of the company.
What should one report?
Conduct that is contrary to Tsodilo's business principles" which includes, but is not limited, to:
Failure to comply with any legal obligation;
Danger to the health and/or safety of employees and contractors;
Damage or threat of damage to the environment;
Criminal offences, including money laundering, fraud, bribery and corruption;
Accounting, internal accounting controls, financial reporting and auditing matters;
Miscarriage of justice; and
Deliberate concealment relating to any of the above.
No employee of Tsodilo will be prejudiced for raising, in good faith, violations of our business principles or any legal or ethical concern.
Is it legal?
Is it in line with our business principles"?
Does it feel right?
How will it affect the team and the business as a whole?
Would you be embarrassed or feel guilty if others discover you did not report it?
Do you have a legal obligation to report it?
I want to report what I know but will I be protected?
Q: I want to report what I know, but will I suffer reprisal?
A: Company policy is that no person will suffer for raising, in good faith, violations of the business principles or any legal or ethical concern.
Complaints and Grievance Procedures
Tsodilo seeks to establish a culture of integrity, openness and accountability. The social management system shall include a complaints and grievance procedure for receiving, managing, investigating and responding to stakeholder complaints in a timely and respectful manner. The complaints and grievance procedure must meet the following requirements
A simple, locally appropriate process for receiving, identifying, recording and acknowledging complaints from stakeholders. The process must include options that are free of charge, and must allow for complaints to be submitted directly, anonymously or via third parties, as preferred by the complainant.
A transparent, structured process for investigating complaints, providing fair redress as necessary, and for reviewing outcomes. The process must include: appropriate classification of complaints into Minor, Moderate or Serious; clear accountabilities within the operation, including ensuring that no manager is both the alleged source of complaints and the sole arbiter of the operation's response; and an externally communicated process and timeframe for responding to stakeholders. All Moderate incidents must be reported within 24 hours to divisional management. All Serious incidents must be reported in writing to the President and COO with 5 business days.
An Employee shall in all instances initially bring any work related complaint or grievance to their immediate supervisor. The complaint or grievance shall in all cases practical be submitted in writing. In those instances wherein a written report is not practical the supervisor shall prepare a written report for the employee to initial.
In those instances where the supervisor determines that the issue raised is of a minor nature the supervisor shall endeavour to resolve the issue. A record of the issue and the resolution shall be prepared and submitted to management on a quarterly basis.
In circumstances wherein the supervisor determines that the issue is of a moderate or severe nature the supervisor shall prepare a written report which includes the initial complaint and submit to the President and CEO within 5 days or as soon as practical.
The supervisor shall keep a detail journal of the resolution of any complaint or grievance filed.
All employees shall be informed that they may circumvent the establish procedures for conflict resolution by submitting a complaint or grievance with the Chairman and CEO of the company directly and the procedures for doing so.
Where relevant, Tsodilo operations shall develop specific management plans for the following circumstances:
Indigenous peoples. Tsodilo recognises and respects the special rights and status of indigenous peoples. Operations shall develop a formal plan for interactions with any communities of Indigenous People impacted or potentially impacted by their activities. Plans shall, as a minimum, meet the requirements set out in the International Finance Corporation's (IFC) Performance Standard Number 7 on Indigenous People (10).
Cultural heritage. Tsodilo seeks to protect and, where possible, enhance the value of the cultural heritage of associated communities. Tsodilo also seeks to ensure that benefits arising from the use of cultural heritage for Tsodilo's business purposes, e.g. in environmental baseline studies, are equitably shared. The management of cultural heritage must meet or exceed the requirements set out in IFC Performance Standard Number 8 on Cultural Heritage.
Where there is no established Tsodilo policy or standard, the IFC Environmental and Social Performance Standards(11) shall be taken as a basis for management planning. Other Performance Standards will be developed as appropriate to meet operational needs or stakeholder expectations.
*Stakeholder shall be defined as follows:
Local government authorities
Non-governmental and other civil society organizations