Purpose
The purpose of this policy is to establish an adequate and effective due diligence process to identify, assess, and mitigate significant actual and potential ethics risks. This policy ensures that all employees, from senior managers to workers, understand their ethical responsibilities and operate within a framework that promotes ethical integrity, compliance, and accountability.
Scope
This policy applies to all employees, contractors, and representatives associated with ALOIS, covering ethics due diligence, responsibilities, monitoring processes, investigations, and ethics training.
Ethics Due Diligence Process
ALOIS will conduct a structured due diligence process to identify and assess ethical risks related to its operations, ensuring compliance with legal and industry standards.
Conduct periodic risk assessments to identify actual and potential ethics risks in operations and supply chains.Categorize risks based on likelihood and severity of impact.Engage relevant stakeholders (employees, suppliers, community representatives) to gain insights into ethical concerns.Establish reporting mechanisms to detect early signs of ethical risks.Ethical Responsibilities and Authorities
Senior Representatives: Oversee and enforce ethical policies and accountability.Managers: Ensure adherence to ethical guidelines and train employees.Workers: Follow ethical standards and report ethical concerns.Ethics Policies and Control Processes
Code of Ethics and Conduct outlining expected behavior.Conflict of Interest Policy to prevent unethical decision-making.Anti-Bribery and Corruption Policy.Whistleblower Protection Policy to encourage ethical reporting without retaliation.Monitoring and Control Processes
Regular audits and reviews to assess adherence to ethical policies.Implementation of a monitoring framework for ethics violations.Anonymous reporting mechanism (via whistleblower).Ethics performance reviews integrated into employee evaluations.Investigation and Sanctions Process
Conduct investigations promptly and impartially when ethical breaches are reported.Apply sanctions proportionate to the severity of violations (e.g., warnings, suspension, termination, legal action).Maintain transparent documentation of ethics investigations and disciplinary actions.Ethics Training and Awareness Program
Ethics training for all new employees as part of onboarding.Training modules covering the Code of Ethics, reporting mechanisms, and case studies.Interactive training sessions, workshops, and e-learning resources.Employee assessments to ensure comprehension and compliance.Compliance and Continuous Improvement
Regularly update ethics policies to reflect legal changes and industry best practices.Encourage a culture of ethical decision-making through leadership and role modeling.Solicit feedback from employees on the effectiveness of the ethics program.Conduct external reviews when necessary to benchmark against best practices.Reporting and Accountability
Employees must report ethics concerns via whistleblower mechanisms.Senior management is responsible for ensuring adherence to this policy.
