WHISTLE BLOWING POLICY

International Packaging Industries Plc (“IPI”/”the Company”)) requires Directors, Officers and Employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. Employees and representatives of IPI must practice honesty and integrity in fulfilling their responsibilities and must comply with all applicable laws and regulations.

This Policy establishes Guidelines for managing a whistle blowing mechanism for reporting wrongdoing within the Company.

2. Objectives

The Whistleblower Policy is intended to encourage and enable employees and stakeholders such as contractors, shareholders, job applicants, and the general public to raise serious concerns internally to enable IPI address and correct inappropriate conduct and actions. It is the responsibility of all Board members, officers, employees and volunteers to report concerns about violations or suspected violations, of law or regulations that govern the Company’s operations.

Efforts will be made to bring the existence of the Company’s Whistle Blowing mechanism to the knowledge of all staff and other stakeholders, including through inclusion on IPI’s Website.

3. No Retaliation
It is contrary to the values of IPI for anyone to retaliate against any person who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of the Company.

4. Whistle Blowing Procedure

All Whistle blowing complaints shall be lodged through the Company’s website and not from a complainants’ personal email in order to guarantee the anonymity of the complainant.

The following officers shall be recipients of the whistle blowers’ email messages:

• The Chairman of the Board Risk, Compliance & Audit Committee.
• The Managing Director/CEO

The Board shall have the responsibility to support the Company’s whistle-blower protection mechanism for reporting any illegal or substantial unethical behavior which shall be accorded priority by the Board.

5. Lodgment of Complaints

The Managing Director shall consult with the Chairman of the Board Risk, Compliance and Audit Committee on the line of action to take. In situations where information is received and the Managing Director/CEO does not initiate the process of investigation, the Chairman of the Board Risk, Compliance and Audit Committee may initiate the investigating process.

A Whistleblowers Report shall be compiled from time-to-time and at least Quarterly and reported to the Board Risk, Compliance and Audit Committee.

6. Good Faith
Any person filing a written complaint concerning a violation or suspected violation must act in good faith and have reasonable grounds for believing the information disclosed indicates a violation.

7. Review Period
This Policy shall be reviewed as deemed necessary.

Approved by the Board of Directors

The 18th day of March 2021