The BGL Whistleblower system

Russel Company is committed to maintaining the highest standards of integrity, transparency, and ethical conduct. This policy provides a secure and confidential process for employees, contractors, suppliers, and stakeholders to report concerns about unethical or illegal activities without fear of retaliation.

1. Purpose

This policy ensures that individuals can report misconduct in a safe and confidential manner. Russel Company encourages openness and accountability while safeguarding whistleblowers from any form of discrimination or retaliation.

2. Scope

This policy applies to all employees, suppliers, contractors, and business partners associated with Russel Company.

3. Reportable Concerns

Whistleblowers should report any concerns related to:

• Fraud, theft, or financial misconduct
• Corruption, bribery, or conflicts of interest
• Violations of company policies or regulatory compliance
• Workplace harassment, discrimination, or unethical behavior
• Environmental or safety breaches

4. Reporting Channels

• Internal Reporting: Concerns can be reported confidentially to a supervisor, manager, or the designated Whistleblower Officer at reports@russellandcologistics.com.
• External Reporting: If an individual is uncomfortable reporting internally, they may contact a regulatory body or relevant legal authorities.

5. Confidentiality & Protection

• All reports will be treated with strict confidentiality, and the identity of the whistleblower will be protected unless legally required to disclose it.
• Russel Company strictly prohibits retaliation against any individual who reports concerns in good faith. Employees who engage in retaliation will face disciplinary action, including possible termination.

6. Investigation Process

• All reports will undergo an initial assessment to determine credibility and severity.
• If necessary, a full investigation will be conducted, which may involve interviews, document analysis, and expert consultations.
• The whistleblower will be kept informed of progress where possible.

7. False Reports

Russel Company takes whistleblower reports seriously. However, deliberately making false or malicious allegations will be considered a serious offense, subject to disciplinary action.

8. Review & Amendments

This policy will be reviewed periodically to align with legal and operational changes. Any updates will be communicated to all stakeholders.

For further inquiries, please contact the Whistleblower Officer at reports@russellandcologistics.com.