1. Purpose

RGE is committed to maintaining the highest standards of ethical conduct, integrity, compliance with applicable laws and regulations, and responsible corporate governance in all of its business activities.

RGE encourages the reporting of any instances of suspected unethical, illegal, fraudulent or undesirable conduct, and will ensure that those persons who make a report shall do so without fear of intimidation, disadvantage or reprisal. 

2. WHAT IS REPORTABLE CONDUCT?

You may make a report under this policy if you believe that a RGE director, officer, employee, contractor, supplier, tenderer or other person who has business dealings with the company has engaged in conduct (Reportable Conduct) which:

​is dishonest, fraudulent or corrupt activity, including bribery or other activity in breach of the 

​Anti-bribery Policy;

​is illegal activity (such as theft, drug sale or use, violence, harassment or intimidation, criminal 

​damage to property or other breaches of state or applicable Myanmar laws, regulations and 

​regulatory requirements);

​is unethical or in breach of policies (such as dishonestly altering company records or data, 

​adopting questionable accounting practices or willfully breaching Code of Conduct or other 

​policies or procedures);

​is potentially damaging to RGE, an employee or a third party, such as unsafe work practices, 

​reputational damage, health risks or abuse of property or resources owned by the Company;

amounts to an abuse of authority, rights, privileges or responsibilities;

may cause financial loss & detrimental to company’s interests;

4. INVESTIGATION OF REPORTABLE CONDUCT

 RGE Senior Management or the designated investigation team will assess and investigate all matters reported under this Policy as soon as reasonably practicable after receiving a report.

The Whistleblower Compliance Officer may appoint an appropriate person or investigation team to assist with or conduct the investigation, depending on the nature and complexity of the matter.

The Whistleblower Compliance Officer will provide appropriate updates to the whistleblower regarding the progress and/or outcome of the investigation, where possible, subject to legal obligations, confidentiality requirements, and the privacy rights of persons involved in the allegations.

All investigations will be conducted in an objective, fair, independent, and confidential manner. The investigation process will be conducted having regard to the nature of the Reportable Conduct, the circumstances of the matter, and applicable Company policies and procedures.

5. PROTECTING THE WHISTLEBLOWERS​

RGE is committed to protecting whistleblowers by ensuring confidentiality in relation to all matters reported under this Policy. Any person who makes a report in good faith will be treated fairly and will not suffer any disadvantage, retaliation, or adverse treatment as a result of making a report.

(a) Protection of your identity and confidentiality

Subject to applicable laws and regulatory requirements, RGE will take all reasonable steps to protect the identity and confidentiality of a whistleblower.

Upon receiving a report under this Policy, Supervisors, Managers, Directors, and the Whistleblower Compliance Officer must not disclose any information that may identify or reasonably lead to the identification of the whistleblower without obtaining the whistleblower’s consent, except where disclosure is required or permitted by law.

Where a whistleblower provides consent for disclosure of their identity, such information will only be disclosed on a strict confidential and need-to-know basis.

(b) Protection of files and records

All files, documents, and records created or obtained during an investigation under this Policy will be securely maintained and protected against unauthorized access, use, or disclosure.

Any disclosure or release of information relating to a whistleblower report or investigation to a person who is not involved in the investigation, without the whistleblower’s consent, will constitute a breach of this Policy, except where such disclosure is required for appropriate action by authorized senior management, directors, or for legitimate corporate governance purposes.

Whistleblowers are assured that any unauthorized disclosure of confidential information in breach of this Policy will be treated as a serious matter and may result in disciplinary action in accordance with RGE’s Disciplinary Policy.

(c) Fairness

RGE is committed to ensuring that any employee, contractor, or other person who makes a report in good faith under this Policy is treated fairly and does not suffer any detrimental treatment, retaliation, or adverse consequences as a result of making such a report.

Any employee or contractor who believes that they have been subjected to detrimental treatment because of making a report under this Policy should immediately report the matter to their senior supervisor, manager, executive officer, Human Resources Department, or the Whistleblower Compliance Officer.

If the matter is not appropriately resolved, it should be escalated through the reporting channels established under this Policy.

Detrimental treatment includes,

• Dismissal or termination of employment; 

• Demotion or unfair disadvantage; 

• Harassment or intimidation; 

• Discrimination; 

• Disciplinary action; 

• Bias; 

• Threats or other unfavorable treatment 

RGE will comply with applicable Myanmar laws and regulations regarding the protection of persons who make disclosures concerning suspected breaches of legal requirements, including relevant provisions under the Myanmar Companies Law 2017.

6. DUTIES OF EMPLOYEES

Employees who become aware of actual, suspected, or potential cases of Reportable Conduct are expected to report such matters in accordance with this Policy or other applicable Company policies and procedures.

Employees are encouraged to raise concerns promptly and provide accurate information to support appropriate assessment and investigation.

Failure to report serious or known instances of Reportable Conduct may be considered a breach of this Policy and may result in disciplinary action in accordance with RGE’s Human Resources Disciplinary Policy.

7. REPORTING PROCEDURES

The Whistleblower Compliance Officer will provide periodic reports to RGE Senior Management and/or the Board of Directors regarding whistleblower matters received under this Policy.

Such reports may include:

The number of whistleblower reports received;

The nature and category of concerns reported;

The status of investigations;

Significant findings and corrective actions taken.

All reports will be prepared on a confidential and anonymous basis to ensure that the identity of whistleblowers and persons involved in investigations is protected.

Serious, significant, or material Reportable Conduct may be escalated by the Whistleblower Compliance Officer to Senior Management and/or the Board of Directors for appropriate review and action.

The Company will ensure that whistleblower matters are managed in accordance with this Policy, applicable laws, and good corporate governance principles.

8. DIVISIONAL/BUSINESS UNIT POLICIES

 Where RGE operates through different departments, business units, or operational functions, specific procedures or reporting arrangements may be established to address the particular requirements of those areas.

Any department or business unit-specific whistleblower procedures must be consistent with this Whistleblower Policy. In the event of any inconsistency between a department or business unit procedure and this Policy, this Policy shall prevail.

RGE may establish appropriate confidential reporting channels, including an independently managed reporting hotline or other communication channels, to support effective implementation of this Policy.

9. AMENDMENT OF THIS POLICY

 This Policy may not be amended, revised, or replaced without approval from the RGE Board of Directors or an authorized management committee.

RGE will review this Policy periodically to ensure that it remains effective, appropriate, and aligned with applicable laws, regulatory requirements, corporate governance principles, and recognized best practice standards.

Any amendments to this Policy will be communicated to relevant employees and stakeholders as appropriate.