Whistle-blower policy

In accordance with its Whistle-blower policy all Pembani-Remgro employees and third parties, including personnel at portfolio companies, are encouraged to come forward if they have concerns about suspected serious misconduct or any breach or suspected breach of law or regulation.

Whistle-blower reports can be made to info@pembani-remgro.com.

The Principles

  1. The Pembani-Remgro welcomes whistle-blower reports and encourages staff to draw to its attention instances of corporate wrong-doing within the Pembani-Remgro group of companies.
  2. The Company will require that every business in which the capital of the funds that it manages/advises is invested adopt and implement Whistle-blower policies in accordance with local laws and international best practices.
  3. The Company regards attempts to victimise or discriminate against a Whistle-blower as potentially gross misconduct.

A Whistle-blower Report concerns as a reasonably held concern that:

  • A criminal offence has been committed, is being committed or is likely to be committed;
  • A person has failed, is failing or is likely to fail to comply with any legal obligation to which he or she is subject;
  • A miscarriage of justice has occurred, is occurring or is likely to occur;
  • The health and safety of any individual has been, or is being or is likely to be endangered;
  • The environment has been, is being or is likely to be damaged;
  • Information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed; and
  • A concern raised in good faith that discloses or demonstrates information that may evidence serious unethical or improper activity within Pembani-Remgro (or a company in its group) and its and their business practices.

This policy relies upon the reasonable belief of staff and it should not be used as a mechanism for raising malicious or unfounded allegations against colleagues. Such practices may themselves be grounds for disciplinary proceedings.

Pembani-Remgro will ensure that:

  • the identity of a Whistle-blower is kept confidential and only disclosed on a need to know basis;
  • papers relating to a Whistle-blower Report are filed carefully away;
  • instances of victimisation of a person making a Whistle-blower Report are treated as a serious matter which may give rise to disciplinary action by Pembani-Remgro against any person(s) causing or allowing such victimisation.

These protections may be lost if a disclosure is made maliciously.

A dedicated individual at Pembani-Remgro will conduct the investigation of any such reports and we will seek to progress them as quickly as possible. We will, so far as we are able, keep you informed of our investigations. Once any investigation by Pembani-Remgro is concluded, you will be provided with a summary of the outcome, again in so far as we are permitted to by law and/or confidentiality obligations.

Pembani-Remgro’s Board will oversee the handling of all whistle-blower reports that raise material issues.