Investigation responsibilities

The Fraud Investigation Officer and Legal staff has the primary responsibility for the investigation of all suspected fraudulent acts as defined in this policy. The investigation team may include members of other departments who have investigatory skills and experience. If the investigation substantiates that fraudulent activities have occurred, the Fraud Investigation Officer, Internal Audit or Legal Departments will issue reports to appropriate designated personnel and, if appropriate, to the Board of Directors through the Audit Committee.

Any questions relating to fidelity insurance claims and legal matters, including compliance Data protection provisions and human Rights will be referred to the Chief Legal Officer.

The Company policy is to prosecute. The decision to prosecute or report matters to the police and/or regulatory agencies for independent investigation will be made in conjunction with the C.E.O., the Chief Legal Adviser and Business Unit Heads, as will final decisions on disposition of the case.