Whistleblowing Procedure

WhistleblowingProcedure

The North Oil Company Whistleblowing Procedure

North Oil Company, hereafter referred to as “The Company”, commits to ethical business practices that are done with the highest levels of integrity in line with our values and business principles.

Unauthorised or unethical acts by The Company are not tolerated and are subject to a whistleblowing procedure. This procedure allows anyone within The Company to report concerns, breaches of The Company’s Code of Ethics, or illegal acts to our Whistleblowing Department.

Complainants include:

● Employees
● External stakeholders
● Contractors
● Business partners
● Employees of The Company’s suppliers
● Former employees

Responsibility for preventing, reporting, and investigating acts of fraud within NOC

Fraud, corruption, and acts of discrimination based on gender, religious belief or sexual orientation are a big problem faced by companies today. With the risk of damaging consequences for the employees and The Company, all parties have a responsibility to report any incidents of misconduct as per The Company’s Code of Ethics. This responsibility extends to suppliers, shareholders, and other stakeholders listed above who have a vested interest in the success of The Company and the State of Qatar.

North Oil Company does not and will not tolerate action or threats of action against those employees who “blow the whistle” by asking questions or voicing concerns in making their complaints. This is in line with the complainant stating their case truthfully and within the lines of the Code of Ethics. We, as a company, stand by our duty to investigate any areas of concern, including those that result in a breach of the Code of Ethics. All complaints must be referred to the Compliance Officer and The Company’s Internal Audit Division as necessary.

The Company invites all internal and external stakeholders to provide assistance in reporting their concerns to The Company at their earliest convenience.

The Reporting Procedure

Confidentiality when reporting any complaint is essential, and the NOC provides several mechanisms to make reporting as safe and easy as possible. These mechanisms include:
● A link on The Company’s website
● A mailing address to which complaints can be emailed

The link makes use of a username and password that is required for assistance with any future investigations pertaining to the claims or complaint.

Should the complainant wish to remain anonymous, they can write to the Compliance Officer or Audit Corporate Manager at the following address:

North Oil Company
P.O. Box 21264
Doha
Qatar

Confidentiality

All complaints and reported concerns will be reviewed by either the Compliance Officer or The Company’s Internal Audit Division. Should the complaint contain sufficient information to warrant an investigation, all concerns will be corroborated and investigated by the parties mentioned.

Reporting Guidelines

What to report through The Company’s whistleblowing procedure:

● Any and all concerns or information pertaining to potential fraud or illegal activities in which The Company, its employees, or its divisions are involved
● Concerns or information regarding unethical behaviour by The Company or its employees
● Concerns or information on possible fraudulent activity carried out by The Company, its employees, contractors, and other outside parties

What not to report through The Company’s whistleblowing procedure:

● Any and all concerns of a personal nature, including those that relate to compensation or benefits
● Safety or security concerns that should be addressed to the HSEQ
● Any concern that falls within the scope of a designated division or person