Incident Reporting & Whistleblowing Policy

This policy was established to govern reports made to Sawari Ventures of unethical or criminal behavior at the organization or its portfolio companies.

DEFINITIONS:

Employee	means any individual who is employed by Sawari Ventures
Representative	means any individual representing Sawari Ventures in a contractual relationship (such as partners, members of the investment committee, members of the board etc.)
Whistleblowing	means the sounding of an alarm by an employee, director, or external person, in an attempt to reveal neglect or abuses within the activities of an enterprise (or one of its third parties) or other organization that threaten public interest or the entity’s integrity and reputation.
Good faith	means all reporting made with a reasonable basis for the suspicion of unethical or illegal behavior. Good faith shall be considered lacking where the reporting individual knew, or ought to have reasonably known, that the reporting and underlying incident was malicious or false.
Unethical or illegal behavior	includes any behavior violating applicable Egyptian law, our Code of Conduct, and our general ESG requirements.
Retaliation	means a direct or indirect adverse administrative decision and/or action that is threatened, recommended or taken against a whistleblower or an individual who has reported suspected wrongdoing that implies a significant risk; or an Individual who cooperated with a duly authorized audit or an investigation of a report of wrongdoing.

Policy:

We expect all of our employees and representatives, as well as employees and representatives of our portfolio companies, to follow applicable law as well as our Code of Conduct and other relevant policies and standards at all times.

We encourage our stakeholders (including, but not limited to, our employees, representatives, employees or clients of our portfolio companies) to alert us of any unethical or illegal behavior encountered in relation to Sawari Ventures or any of our portfolio companies.

While our reporting channels can be used for any complaint about illegal or unethical behavior made in good faith, this policy expressly covers instances of the following behavior:

illegal conduct, such as theft, dealing in, or use of, illicit drugs, actual or threatened violence,
criminal damage to property or breaches of work health and safety laws;
corruption, bribery, fraud, money laundering or misappropriation of funds;
negligence, breach of trust or breach of duty;
conduct relating to business behaviors and practices that may cause consumer harm;
conduct that represents a danger to the public or the financial system;
sexual harassment (verbal, physical or in writing) or assault
bullying or other psychological violence, especially if made due to characteristics surrounding ethnicity, religious or political beliefs, (physical) disability, gender expression or orientation, among others.

Reports can be made directly to any of our management or staff or through a dedicated reporting line (anonymously or not).

Individuals may choose to submit reports anonymously and may choose to list as much or as little detail as they feel comfortable sharing. However, the more detail is provided, the likelier we will be able to undertake a thorough investigation of the incident in question.

Anyone reporting an incident under this Policy should act in good faith and have reasonable grounds for believing the information disclosed to be accurate and indicate a violation.

If we have reason to believe that reports were made in bad faith (i.e. the reporting individual knowingly submitted incorrect information, with the aim to defame or injure a person), we reserve the right to investigate the matter and take disciplinary action as applicable and feasible.

We commit to investigating any report made in good faith as swiftly and thoroughly as possible.

If a reporting individual wishes to be included in the investigation or response, we will contact him/her following the report made.

Reports of violations or suspected violations will be kept confidential to the largest extent possible, consistent with the need to conduct an adequate investigation.

Where accusations against an employee or representative of Sawari Ventures or any of our portfolio companies are confirmed in an investigation, swift action will be taken accordingly. This may include disciplinary measures up until termination of the relationship if severe breaches of our policies or values are found to have occurred.

Credible claims of illegal or criminal behavior may be reported to the relevant authorities (unless the reporting individual or victim of the behavior explicitly asks us not to).

Credible claims of behavior that violate our Code of Conduct or other policies but fall short of illegal or criminal behavior will be handled internally.

An employee who in good faith reports a violation shall not suffer harassment, retaliation or any prejudice. Any employee who retaliates against someone who has reported a violation in good faith shall be subject to disciplinary action.

To the extent we are able to, we will ensure that reporting individuals are protected from retaliation in response to reports made in good faith.