JUBILEE INSURANCE WHISTLEBLOWER POLICY

The Jubilee Insurance Group (“Jubilee Insurance”/ “the Group”) values feedback and considers a transparent speaking-up culture and environment, as well as being open to and taking seriously criticism and complaints, as a vital part of our corporate culture. Feedback allows the Group to discover areas for improvement, improve the quality of work, and increase stakeholder trust and confidence in the organization.

In line with the above, this Policy is intended to provide various channels for articulating suggestions on process improvements or reporting actual or suspected wrong doings committed by any staff, supplier, service provider, contractor or other stakeholders dealing with Jubilee Insurance for investigation and appropriate action. Any stakeholder including staff that choses to speak-up/whistle blow in good faith will be protected from reprisals, retaliation, or any adverse treatment.

Policy statement

Jubilee Insurance is committed to the highest standards of honesty, openness, and accountability. It aims to ensure that it operates in a responsible manner, considering ethical business standards set by the Board of Directors. It recognizes that all stakeholders have an important role in helping to achieve this aim.

Purpose

The purpose of this Policy is therefore to assist and enable staff members and external stakeholders to raise concerns or to disclose information which they believe, in good faith, may indicate malpractice.

The policy aims to-

• Encourage employees and external parties to report suspected wrongdoing as soon as possible, knowing that their concerns will be taken seriously and investigated, and that their privacy will be protected.
• To provide employees and other stakeholders with guidance as to how to raise those concerns.
• To reassure employees and external parties that they should be able to voice concerns without fear of retaliation, even if their concerns turn out to be unfounded.
• To establish a procedure for reporting, investigating, and resolving any workplace wrongdoing, including specifying the roles and responsibilities for reporting and investigating claims of wrongdoing.

Scope of the Policy

The scope of this policy requires report of the following types of incidents.

• Fraud, corruption, bribery, solicitation, theft, and all forms of financial malpractice or impropriety.
• Conflict of Interest situations and non-disclosure of the same.
• Fraud and any form of criminal activity.
• Improper conduct or unethical behavior, including any offence under the Bribery Act, 2016 or any behaviour that undermines universal and core ethical values such as integrity, respect, honesty, accountability, and fairness etc.
• Failure to follow legal requirements, statutes, and regulatory directions.
• Other types of corporate governance violations including transactions that have not been disclosed or recorded in accordance with regulations or human rights violations.
• Failure to comply with the Code of Conduct and any rules and 5 regulations that may be prescribed by the Group from time to time.
• Suspected criminal activity.
• Non-adherence to Group’s policies and procedures.
• Any action taken by a professional, executive, manager, or officer that is deemed to be contrary to expected proper behaviour or ethical norms.
• Any employee, customer, service provider, or other relevant stakeholder who is sexually or physically abused or under threat of the same.
• Environmental, health and safety issues.
  Attempts to conceal any of the above listed acts.

Confidentiality

The identity of the individual making an allegation will remain confidential, unless otherwise agreed with that individual that disclosure is necessary.

Roles and Responsibility

Whistle blowers.

Whistle blowers may be Company employees and intermediaries under the group, applicants for employment, vendors, contractors, customers, and the public.

When expressing their concern(s), the ‘whistleblower(s)’ are expected to act in good faith and not make false charges, as well as give any further evidence available to aid in the examination of the issues raised. The Adversely Mentioned person on the other hand will have the right to know that a complaint / report has been made in which they are adversely mentioned and will have the responsibility for complying with investigators as well as the right to be heard.

Investigators

The Investigator(s) is expected to treat all concerns with seriousness, confidentiality, and promptness. In conducting the investigation, he or she must be impartial and independent.

Human Resource

The Head of HR will be responsible for noting all reported concerns and updating the ‘Speaker’ on the investigation’s progress. He or she must present a summary of all cases reported and the results of the investigations to the Board Human Resource Committee (BHRC) on a quarterly basis and then BHRC will channel the report accordingly to the relevant Board Committee. The Head of Human Resources is responsible for acting on investigations involving group employees in accordance with the disciplinary procedure outlined in the HR Policies and Procedure Manual.

Whistleblowing Mechanisms

Any individual who has observed reportable misconduct can report his/her concerns to designated parties as prescribed by this Policy provided, they are made in good faith, and the disclosure is true and reasonable.

All staff should ensure that appropriate steps are taken to disclose any wrongdoing or malpractice of which they become aware as non-action/ concealment will be deemed as complicity.

The disclosure should be made to an appropriate person or authority through the following mediums.

Tip-offs Anonymous

Log on to www.tip-offs.com which provides an anonymous reporting for unethical behaviour. In addition, call the Toll-Free number 0800 722 626 or write to jubilee@tip-offs.com.

Formal email or letter.

The Board: tip-offs@jubileekenya.com

The Group Chairman: chairman@jubileekenya.com

The Group CEO: GroupCEO@jubileekenya.com

Investigation Procedures

The investigation will be conducted as quickly and fairly as possible. While it may be impossible to provide a specific time limit for the conclusion of the inquiry due to the wide range of potential problems, the Head of Human Resources will make every effort to resolve any concerns within four (4) weeks. If this deadline is not met, a status update will be issued at the end of the four weeks, and then every four weeks following until the inquiry is completed. If a proper resolution cannot be reached within this time range for any reason, the Investigator shall inform the Group CEO or other competent authorities.

Non-Retaliation

This is when the ‘Whistleblower’ or any other person who supports the ‘Whistle-blower’s’ claim is subjected to retaliation. The Group’s approach will be one of zero tolerance for retaliation. The following will be considered as means for retaliation:

1. Dismissal, suspension, demotion, harassment, or intimidation.
2. Being subjected to disciplinary action of any kind including being transferred against one’s will or being turned down for a transfer or a promotion.
3. Being adversely impacted in connection with ‘Whistleblower’s’ job, profession, or office.
4. A unilateral change in a term or condition of employment or retirement to the detriment of the employee.
5. The employer refusing to furnish a reference or providing a negative reference or being turned down for an appointment.
6. Harassment, stigmatization, and threats of any form are prohibited.

The Group will provide frequent training to all employees, with a special focus on managers and supervisors, to address their unique roles in assessing the company’s retaliation monitoring process. Clear indication that, after a prima facie demonstration of retribution against the ‘Whistleblower(s)’, the responsible management will have to prove that actions taken against the ‘Whistleblower(s)’ were motivated by factors other than the disclosure.