This applies to all EDB stakeholders including staff members, customers, any person/party providing EDB with services, consultants and any party dealing with EDB.  (Grouped together for the purposes of this document under the term “stakeholder(s)”)

POLICY COVERAGE

This Policy covers Concerns about actual or suspected irregularity or misconduct of a general, operational or financial nature within EDB, including but not limited to:

• Criminal Actions and behavior
• Non-compliance with laws and regulations.
• Accounting, internal accounting controls or auditing matters;
• Money laundering or terrorist financing;
• Unfair and/or Inappropriate people management including Discrimination, Harassment, etc.
• Breach of (client) confidentiality or privacy;
• Theft; and Fraud.
• Any action that is classified as bribery,  corruption, extortion, collusion or coercion in order to have direct or indirect benefit for self or for others.
• Market abuse.
• Insider trading.
• Exposing any party to HSE hazards.
• Any action that harm the environment.
• Any unethical behavior.
  Hiding or concealing any information about any of the above items.