Whistle-Blower Policy

1. Purpose

Eccentex is committed to the highest levels of ethics and integrity across all business functions.  The purpose of this policy is to encourage the Board of Directors, staff (paid and volunteer) and others including suppliers and vendors of Eccentex, to report without retribution, suspected or actual occurrence(s) of illegal, unethical, or inappropriate events, behaviors or practices.

2. Scope

This policy applies to all Employees of Eccentex (Company), including permanent, temporary and contractual (direct/indirect) who may have an appropriate matter to report (“Subject”).  Wrongful conduct includes but is not limited to the following:

• Financial or non-financial malpractice – fraud, corruption, bribery, theft, money-laundering;
• Harassment, abuse and misuse of power and authority;
• Non-compliance with applicable laws and regulations;
• Any conduct that may be detrimental to the physical or mental health and safety of an individual or unnecessarily detrimental to the Company’s working environment;
• Discrimination based on age, religion, race, sexual orientation or disabilities;
• Material conflict of interest without disclosure; and
• Breach of Eccentex bylaws, policies or internal controls, including the Information Security Policy.

3. Guiding Principles

To ensure adherence to this Policy, and to assure stakeholders that any such concern raised hereunder will be acted upon seriously, Eccentex shall:

• Ensure that the Whistle-Blower and the person processing the Protected Disclosure are not victimized for doing so;
• Treat victimization as a serious matter, including initiating disciplinary action on person/(s) indulging in victimization;
• Ensure complete confidentiality;
• Not attempt or allow any stakeholder to attempt to conceal evidence from the investigation;
• Take disciplinary action if anyone destroys or conceals evidence from the investigation; and
• Provide an opportunity for the persons involved to be heard fairly and openly (within the bounds of confidentiality) especially the Whistle-Blower and the Subject.

4. Procedure for Reporting and Dealing with Disclosures

• Any Employee, vendor, service provider or any other party who becomes aware of any unfair practice or malpractice may make a written disclosure of the same via email to any member of the Whistle-Blower Committee.
• Changes to the Whistle-Blower Committee, as applicable, will be updated from time to time in this policy, and in those places where this policy is referenced.
• Stakeholders unwilling or unable to disclose a matter in writing may approach any member of the Whistle-Blower Committee directly or through their superior or any other Employee.
• Any such disclosure will be treated as confidential to the person raising the issue, the person to whom the issue is raised, and the Whistle-Blower Committee.
• The member of the Whistle-Blower Committee who receives the notification will prepare a written summary of the disclosure and the Whistle-Blower Committee will take any necessary actions through investigations conducted confidentially.
• For any Whistle-Blower event, the Whistle-Blower Committee may appoint a Whistle Officer, who shall outline the detailed procedure for an investigation.
• The Whistle-Blower Committee and the Whistle Officer, if appointed, shall have right to call for any information, document or examination of any Employee, or other persons as deemed appropriate, for the purpose of conducting investigations under this policy.
• After the investigation is complete, a report will be prepared for the Whistle-Blower Committee’s consideration. After considering the report, the committee shall determine the course of action and may order for remedies as they deem fit. Care will be taken to protect the Whistle-Blower and the Subject throughout this process, especially in the situation where improper conduct is not deemed to have occurred.