Whistle-blower Policy

The Bylaws of the PT Global Plastic Trading and Global Plastic Trading Pty Ltd (GPT) require GPT employees, representatives, directors, members, and committee and team participants to practice the highest standards of business ethics and comply with all applicable laws and regulations while fulfilling their duties and responsibilities on behalf of or in their involvement with GPT. It is GPT’s intent to remain in compliance with all laws and regulations governing its activities, including but not limited to those addressing business competition, corrupt practices, and corporate accountability. It is therefore their responsibility to reports uspected violations of business ethics and legal requirements in accordance with this Whistle-blower Policy.

It is against GPT policy for any of its employees, representatives, directors, members, or committee or team participants to harass, take disciplinary action, or otherwise retaliate against an employee who in good faith reports a suspected violation. An employee who retaliates against someone who has reported a suspected violation in good faith is subject to disciplinary action up to and including termination of employment. This policy is intended to encourage and enable employees to report suspected violations without fear of retaliation and to foster an ethical work environment.

Directors, members, representatives, and committee and team participants shall report suspected violations to the Board Chair who, in the case of allegations concerning employees, will notify the GPT Chief Operations Officer (COO). GPT employees shall report suspected violations to their direct supervisor and/or GPT’s lead on human resource matters. Supervisors are required to report suspected violations to the GPT’s COO or General Counsel, each of whom has direct access to the Board Chair regarding suspected whistleblowing issues.

In the case of alleged violations concerning GPT directors, members, representatives, and committee and team participants, final action will be handled by the Executive Committee. In the case of alleged violations concerning GPT employees, the GPT COO and/or General Counsel will work with GPT’s lead on human resource issues until the matter is resolved.

Anyone reporting a suspected violation must have reasonable grounds for believing a possible violation has occurred. In the case of GPT employees, allegations that prove not to be substantiated and that prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Reports of suspected violations may be submitted on a confidential basis and will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.