Integrated Gas Company SAOC (IGC or the Company) is consistent in its approach towards achieving full legal compliance within its business practices and to assure a controlled environment of business operations, resting on a solid base of a compliance and governance framework.
In today's corporate landscape, ethical business practices, transparency, and accountability are fundamental to maintaining stakeholder trust and ensuring regulatory compliance. A whistleblowing policy serves as a critical tool for organizations, including IGC as a gas aggregator operating as an entity at the national level, to identify and address misconduct, fraud, corruption, and other unethical behaviours that may impact the organization’s reputation ultimately leading to an impact on the nation.
Given the strategic role of IGC in managing the supply and distribution of natural gas in collaboration with government entities, energy producers, sectors and industrial consumers, maintaining the highest standards of governance is essential. IGC is committed to maintaining the highest standards of governance. Any failure to detect and mitigate wrongdoing can lead to financial losses, legal consequences, reputational damage, and risks to the national energy security of Oman.
A whistleblowing policy empowers employees, contractors, and external stakeholders to report concerns in a safe and confidential manner, ensuring that issues are investigated promptly and appropriately. This policy also reinforces a culture of transparency and integrity, strengthens compliance with Omani laws and regulations, and provides protection against retaliation for those who come forward in good faith to protect the organization.
By implementing a robust whistleblowing framework IGC demonstrates a commitment to ethical business conduct, regulatory compliance, and corporate responsibility, ultimately fostering a more transparent and resilient organization. This document is to be read in conjunction with other relevant reference documents within IGC.
This policy is established to encourage employees, contractors, vendors, producers, transporter, end users and other stakeholders to report, in good faith, any known or witnessed unethical, illegal, or improper conduct within the company. It ensures that, suspected concerns raised are properly investigated and that whistleblowers are protected from retaliation by any party. This encourages open and honest communication, which is crucial to maintain IGC’s integrity and reliability to be entrusted with executing its mandates.
IGC is committed to upholding the highest standards of integrity, transparency, and accountability in all aspects of its business operations. The policy is designed to:
This policy aligns with Omani laws and international best practices in corporate governance, including the Oman Penal Code, the Commercial Companies Law (CCL) of Oman, and guidelines from the Financial Services Authority (FSA) and State Audit Institution (SAI).
The internal legal counsel will be responsible for monitoring the accurate implementation of this policy’s requirements and act as the liaison with all other critical stakeholders for effective execution of this policy requirements. During any period whereby an internal legal counsel is not available to provide support, an external legal counsel may be consulted by the management team to provide support on accurate implementation whenever required. Otherwise, the Line Managers of the business units shall ensure compliance with the policy within each business unit, allowing for an interpretation of compliance at organizational level.
This policy provides the framework for supporting a culture of reporting transparency in managing potential situations of compromise that may impact the organization.
All applicable Laws, Regulations and Ministerial Decisions recommendations, including those which prove to influence the Company’s and its direct stakeholder business practices, shall be identified and assessed for awareness of the impact on Company mandates and business operations as part of the investigative process once a report is received by a whistleblower.
This policy applies to all IGC employees, contractors, vendors, producers/suppliers, transporter, end users and other stakeholders and shall be used as a reference at all times. It provides the ability for any involved party to IGC’s business to make a whistleblowing report whenever necessary.
A robust whistleblowing framework is essential for:
This policy covers reporting concerns related to:
| Applicable Law | Means any law, statute, rule, royal decrees, regulations, orders or administration/ ministerial decisions of any governmental authority which has the authority to regulate the gas sector (including IGC) in Oman or decisions having similar effect. |
| Board of Directors (BOD) | The Board of Directors of the Company |
| Business Excellence Team | The team in the Company that is tasked with achieving business operations excellence including, inter alia, in leadership alignment, strategy, corporate planning, information management, policies, processes, controls, etc. |
| CEO | Chief Executive Officer of IGC. |
| CFO | Chief Financial Officer of IGC. |
| Internal Auditor | The internal auditor of the Company who is tasked with providing independent and objective evaluations of the Company’s financial and operational business activities and to ensure that the Company follows proper procedures and function efficiently within the remits of certain controls, compliance and governance criteria. |
| Legal Counsel | The in-house legal counsel of the Company or other external counsel specifically designated with this task. |
| Line Manager | Business unit leaders within the Company who are tasked with running the specific business unit’s daily operations, providing management oversight, steer and leadership guidance to the employees. |
| Ministerial Decision | Principle or Rule (with or without the coercive power of law) employed in controlling, directing or managing an activity, organization, or system, whereas the respective Ministry within the Sultanate of Oman holds the responsibility of enforcement with its own executive |
| Regulation | Principle or rule (with or without the coercive power of law) employed in controlling, directing, or managing an activity, organization, or system. |
| Royal Decree | A Royal Decree is a law issued by the head of state, His Majesty Sultan Haitham bin Tariq Al Said, the Sultan of Oman. Once it is officially issued in public and published in the Official Gazette of Oman, it comes into immediate effect whereas all Ministries within the Sultanate of Oman hold the responsibility of enforcement |
| Shareholder | The shareholder of the Company, being the Government of Oman represented by the Ministry of Finance. |
Whistleblowing is the act of reporting suspected misconduct, illegal activities, or violations of laws and regulations within an organization. This includes issues like corruption, fraud, bribery, financial mismanagement, and breaches of health, safety, and environmental laws. In Oman, it's encouraged to promote integrity and transparency.
Whistleblowing involves reporting issues that impact the public or the organization, such as corruption. A complaint typically involves personal workplace grievances, such as salary disputes or unfair treatment.
Whistleblower reports are handled with strict confidentiality under Omani law. Whistleblowers can report anonymously; however, providing contact details may help facilitate a thorough investigation.
There is no fixed legal deadline for reporting concerns, but it is advisable to report as soon as possible, as delays could make investigations more difficult.
The report will be assessed to determine if an investigation is warranted. If necessary, a formal investigation will be initiated. Authorities may request additional information. If misconduct is confirmed, appropriate legal or disciplinary action will be taken.
Whistleblowers can provide additional information if needed, but participation is voluntary, and protections remain in place regardless of involvement in the investigation.
Whistleblowers may receive general updates on the investigation's progress and final outcome, but specific details might be restricted due to confidentiality laws and internal policies.
To maintain confidentiality and protect the integrity of the investigation, whistleblowers should not discuss the case with colleagues, friends, or external parties. Disclosure may compromise the investigation and could have legal implications.
If an investigation does not substantiate the allegations, the whistleblower will not face any consequences, provided the report was made in good faith. However, knowingly making false accusations may lead to legal or disciplinary action.
Omani labor laws and anti- corruption regulations prohibit retaliation against whistleblowers. If a whistleblower faces adverse actions because of their report, they should report the retaliation immediately to the relevant authorities.
Retaliation includes any adverse action taken against a whistleblower, such as dismissal, demotion, harassment, negative performance reviews, or exclusion from opportunities.
To file a retaliation complaint, the whistleblower must provide proof that they reported a valid concern in good faith, evidence of retaliatory action, and a clear link between their report and the adverse action.