Whistleblower Policy

Still Earth Construction is committed to maintaining the highest standards of integrity, transparency, accountability, safety, and ethical conduct in all areas of its business.

This Whistleblower Policy provides a secure and confidential channel for employees, contractors, consultants, vendors, service providers, business partners, clients, project stakeholders, host communities, and members of the public to report suspected misconduct, unethical behaviour, fraud, corruption, policy violations, safety breaches, or any activity that may negatively affect the Company, its people, assets, projects, reputation, or stakeholders.

All reports made in good faith will be treated seriously and handled in a fair, confidential, and professional manner.

Purpose of the Policy

The purpose of this policy is to encourage the reporting of genuine concerns relating to wrongdoing, malpractice, unethical conduct, fraud, corruption, abuse of office, breach of internal policies, safety violations, environmental concerns, project-related irregularities, or any activity that may adversely affect Still Earth Construction, its stakeholders, projects, assets, operations, or reputation.

Still Earth Construction promotes a culture of openness, responsibility, accountability, and protection for individuals who raise concerns in good faith.

Scope

This policy applies to all employees, directors, management, contractors, consultants, vendors, service providers, business partners, clients, project partners, host communities, and other stakeholders of Still Earth Construction.

It is intended for reporting serious concerns relating to misconduct, unethical behaviour, fraud, corruption, abuse of office, conflict of interest, procurement irregularities, safety concerns, environmental concerns, project-related misconduct, policy breaches, or other irregularities connected to the Company’s operations.

This policy should not be used for personal employment grievances, routine HR complaints, or interpersonal disputes, which should be reported through the appropriate Human Resources or administrative channels.

What Can Be Reported

Concerns that may be reported under this policy include, but are not limited to:

• Fraud, theft, or financial mismanagement
• Bribery, corruption, kickbacks, or conflict of interest
• Procurement irregularities or vendor-related misconduct
• Misuse of company assets, equipment, materials, vehicles, or resources
• Abuse of office, authority, or position
• Breach of company policies, procedures, or approval processes
• Unethical conduct or professional misconduct
• Harassment, intimidation, victimization, or retaliation
• Unsafe work practices or deliberate violation of health, safety, and environmental standards
• Project execution irregularities, concealment of defects, or falsification of project records
• Falsification of documents, reports, invoices, certifications, measurements, or other company records
• Unauthorized disclosure or misuse of confidential company information
• Conduct that may damage the Company’s reputation
• Attempts to conceal any of the above

All reports must be made in good faith and with reasonable belief that the information disclosed is true.

How to Report

Concerns may be reported through any of the approved reporting channels below:

Email: whistleblowers@stillearthconstruction.com
Online Submission: Use the secure form provided on this page.
Alternative Channel: Reports may also be escalated to the appropriate management, internal control, audit, legal, compliance, or human resources representative where necessary.

Where possible, reports should include relevant details such as:

• Date, time, and location of the incident
• Names or details of persons involved
• Nature of the concern
• Department, project, site, vendor, contractor, or process involved
• Supporting documents, images, records, invoices, approvals, measurements, reports, or other evidence
• Any other information that may assist with review or investigation

Reports may be made anonymously. However, providing contact details may assist the Company in obtaining clarification, conducting proper investigation, and providing feedback where appropriate.

Submit a Whistleblower Report

You may use the form below to submit a whistleblower report. Reports may be submitted anonymously. If you would like to receive feedback or provide additional clarification, you may include your contact details.

Confidentiality & Protection

Still Earth Construction is committed to protecting individuals who report genuine concerns in good faith.

All disclosures will be treated with strict confidentiality. Anonymous reporting is permitted, and the identity of a whistleblower will not be disclosed except where required by law, regulation, or where disclosure is necessary for proper investigation and resolution.

The Company prohibits retaliation, victimization, harassment, intimidation, discrimination, or any form of adverse treatment against any whistleblower who raises a concern in good faith.

Any act of retaliation against a whistleblower will be treated as a serious violation and may result in disciplinary action.

Information relating to whistleblower reports will only be shared with authorized persons involved in the review, investigation, resolution, or required escalation of the matter.

How Reports Are Handled

All reports received will be handled in a structured, fair, and timely manner.

Upon receipt, reports will be reviewed and assessed to determine the appropriate course of action. Where contact details are provided, acknowledgment may be sent within a reasonable timeframe.

Depending on the nature of the concern, the matter may be referred to Internal Control, Internal Audit, Legal, Human Resources, Management, HSE, Project Management, or any appropriate review committee.

Investigations will be conducted by authorized personnel or appointed representatives, and appropriate corrective, disciplinary, preventive, or remedial actions will be taken where necessary.

Reports, investigation records, and related documents will be handled confidentially and retained in line with applicable internal record management requirements.

Report handling process:

1. Report received
2. Initial review and assessment
3. Assignment to the appropriate review team
4. Investigation where required
5. Corrective or disciplinary action where necessary
6. Closure and confidential record keeping