Alumina Limited

Complaints Policy (Minor Complaints)

1. Overview

This policy defines the policy and process for staff (officers, employees, consultants and contractors (including their employees) of the Company to lodge a complaint relating to:

  • Unfair or offensive behaviour or treatment;
  • Deliberate breaches of controls;
  • Infringement of Company policies; and
  • Breaches of workplace agreement.

2. Guidelines

Staff are encouraged to use the Complaints process for the reporting of behaviour or activity that is offensive, results in unfair treatment or infringes company policy.

If the matter cannot be resolved with the parties involved or if a staff member feels intimidated to raise the matter directly with the other party they should contact either:

  • General Counsel/Company Secretary; or
  • Chairman of the Audit Committee.

Upon receiving a complaint the General Counsel or Audit Committee Chairman will record the complaint and promptly commence an investigation into the complaint. If there is evidence of criminal activity the police will be informed.

The General Counsel or Audit Committee Chairman will assess the complaint and recommend resolution.

An investigation will generally involve:

  • Informing the staff member about whom the complaint is made;
  • Prepare a report on the investigation with recommendations that is forwarded to the Chief Executive Officer (CEO), or if appropriate, the Chairman of Directors;
  • The CEO or Chairman will determine what action is to be taken; and
  • A copy of the report will be kept on file.

If the nature of the complaint is serious, i.e. it involves suspected breach of the law, unethical behaviour or manipulation of the audit process the staff member can afford themselves protection under the Company's Whistleblower Policy.

3. Responsibilities

Staff need to ensure that their complaint is:

  • well founded and supportable
  • made in a manner consistent with the Company's values

The investigator is required to act impartially and with conviction in assessing a complaint with the individuals and Company's values in mind. The investigator will obtain independent advice on matters outside their knowledge or expertise. They will record the complaint and also document the results of their investigation and recommendations. Personal matters will be treated in confidence.

Matters impacting on company disclosure requirements, controls or risks will be reported to the Audit Committee.