Whistleblower protection policy

1. Globalink Transportation and Logistics Worldwide (the “Company”) is committed to achieving and maintaining the highest standards of openness, integrity and accountability. The Company has zero tolerance for unethical business practices or behavior. To achieve this, senior management has adopted a Whistleblower Policy (the “Policy”) for employees and those (including business partners such as customers and suppliers) who interact with the Company (the “Whistleblower(s)”) to report any whistleblowing incidents that they know of or genuinely suspect have occurred or may occur. The Policy is reviewed from time to time by the senior management of the Company.

The General Director and QHSE-Department are responsible for implementation of this Policy.

2. Whistleblower matters include the following matters relating to the Company:

• violation of legal or regulatory requirements;
• criminal offenses, violation of civil law and miscarriage of justice;
• abuse of position, misconduct or fraud in financial reporting, internal controls or other financial matters of the Company;
• danger to the health and safety of any person;
• damage to the environment;
• violation of the rules of conduct applicable in the Company;
• improper conduct or unethical conduct that may damage the reputation or standing of the Company;
• bribery or corruption;
• intentional concealment of any of the foregoing.

3. The Company will treat all whistleblowing reports (“Report(s)”) in a confidential manner. The identity of the Whistleblower making the Report will not be divulged without the Whistleblower’s consent. However, there may be circumstances in which the Company may be legally obliged to reveal the Whistleblower’s identity. If a Report leads to an investigation by regulators or authorities, it may become necessary for the Whistleblower to provide evidence or be interviewed by the relevant regulators or authorities. In order not to jeopardize any investigation, the Whistleblower is also required to keep confidential the fact that he/she has filed a Report as well as the nature of concerns and the identity(ies) of those involved.

4. Any Whistleblower who raises genuine and reasonable concerns in accordance with this Policy will be treated fairly, including protection from unfair dismissal, retaliation or unjustified disciplinary action. The Company reserves the right to take disciplinary or other action against anyone who retaliates against, threatens or threatens the Whistleblower.

5. Genuine disclosures by the Whistleblower on relevant matters will be investigated promptly. If a Whistleblower makes a false report maliciously, with an ulterior motive, without a reasonable belief that the information in the report is accurate or reliable, or for personal gain, the Company reserves the right to take disciplinary action, including the possibility of dismissal, and other measures to recover any costs, losses or damages incurred as a result of the false report.

6. Reports must be submitted in writing to the Head of Human Resources, or to the QHSE-Department at Kabanbay Batyr 52/1, Almaty, or by email to qhse@globalinlogistics.com. Records of all reports and relevant follow-up actions must be kept centrally in the QHSE-Department.

7. When submitting a Report, Whistleblowers must provide sufficient information on the specific matter, including the reasons for concern, with full disclosure of relevant details and supporting documentation, to enable investigations to be carried out effectively. Although anonymous complaints are permitted, Whistleblowers are encouraged to disclose their identity and contact details so that they can be contacted for further information, if necessary, and to provide feedback on the complaint. An anonymous Report that does not contain clear and adequate information regarding disclosure will not be processed.

8. The General Director has the right to decide whether a matter will be referred for investigation. The format of the investigation will depend on the nature of each matter and Reports may be:

• investigated internally;
• referred to QHSE;
• referred to the Company’s external auditor and/or external regulators.

If there is sufficient evidence to suggest that there is a possible case of criminal offence or corruption, the matter will be referred to the relevant regulators.

9. The General Director authorises an officer to write a letter to the Whistleblower which:

• Acknowledging that the Report has been received.
• Advising whether the matter will be investigated, and if not, the reason(s) thereof.
• If the matter is investigated, advise the results of the investigation wherever reasonably practicable.

This Policy will be published on the Company’s website for public information.