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Ethics and Compliance Grievance Procedure
102-16, 102-17, 103-2, 103-3, 205-3, 307-1, 419-1 102-17, 103-2, 103-3
Apical is committed to conducting all business Apical has set up a robust grievance
activities with integrity and in accordance with handling process for all stakeholders to
strict legal and ethical standards. As a member raise concerns related to our business
of RGE Group, all BoD members and Apical or our supplier’s practices. This helps
employees must adhere to the RGE Global Code to ensure that the standards set out
of Conduct (RGE Code). The RGE Code provides in our policies are being adhered to.
guidance on how employees should behave All grievances raised are dealt with in a
in line with our Core values. The RGE Code is transparent and accountable manner.
disseminated as part of our new hire orientation The grievance process is managed and
programme. The RGE Code provides guidance implemented by our Grievance Steering
on how employees should behave in line with Committee (GSC), Grievance Secretariat,
our values. Stakeholder Engagement Team and
Verification Team.
All employees at Apical has a responsibility to
report illegal, irregular, dangerous or unethical The Apical Grievance Procedure covers
activities, which are in breach of the RGE Code all activities related to the management
and related policies, without the risk of reprisal. of stakeholders’ concerns. Our grievance
Employees should communicate issues to process includes a whistleblowing channel
their reporting manager or a Human Resource and a Grievance Alert System that
representative as a first point of contact. For delivers prompt notifications on matters
more severe cases, employees are encouraged raised against Apical or our suppliers.
to contact the Internal Audit Confidential Hotline. Our process of dealing with a grievance
is illustrated in the diagram on the
Apical complies with the various tax systems in following page with further details
the jurisdictions where we operate. The Group available online.
conducts monthly tax reviews to ensure all key tax
positions such as transfer pricing, cross border In 2020, there were six grievances raised
transactions, tax compliance and tax-planning against our suppliers. These grievances
decisions are taken. Key decision making for were related to sourcing from protected
tax matters are undertaken collectively between areas and clearing of forest. Details of
the Group and the corporate office tax team to the grievances raised is available on our
ensure checks and balances. website. In addition to grievances tracked
at a group-level, each refinery also has
In 2020, there were no cases of breach of the their own grievance management process.
RGE Code, including corruption. There were also Grievances handled at the operational
no significant fines and non-monetary sanctions level are not covered in this report.
for non-compliance with laws and regulations in
the environmental, social and economic area.

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