KONKOLA COPPER MINES PLC
COMPANY POLICY
WHISTLEBLOWING POLICY

Procedure No: KCM-P-02

Revision No : 0

Effective Date, Revision 0 :                               11th November 2008

 1.0 Introduction

2.0 Scope

3.0 Responsibility

4.0 Policy

4.1 Receipts and treatment of Complaints

4.2 Access to Reports and Records and Disclosure
Of Investigation results

4.3 Retention of Records

4.4 Amendment to the policy

5.0 Related documents

6.0 Amendment register

7.0 Definitions

1.0        Introduction
The following procedures have been adopted by the Audit Committee of Konkola Copper
Mine Plc (the “company”) to govern the receipt, retention, and treatment of Complaints and to
protect the confidential, anonymous reporting of the same. These policies and procedures
apply to and are available to all employees of the Company, and all external stakeholders.

2.0        Scope
The policy covers all employees of KCM Plc and external stakeholders.

3.0        Responsibility
The Manger Security shall ensure that the policy is implemented.

4.0        Policy
Employees have the opportunity to submit / report ‘Complaints’ pertaining to the following
areas such as:
a)         providing information to the Security Department or Management which leads to the
prevention of theft and recovery of stolen assets
b)         violations of any rules and regulations applicable to the Company and related to
Accounting, Internal accounting controls and auditing matters
c)         intentional error or fraud in the preparation, review or audit of any financial statement of
the Company
d)         any violations to the Company`s ethical business practices as specified in the
Company`s Code of Conduct policy
e)         any other event which would affect the interests of the business
f)          a reward will be paid to informant and will be authorized by the IBU HEAD in consultation
with the VP Finance and Manager Security subject to the scale of 10% of the value of
the subject matter recovered to a maximum of US$4,000.

The Company will protect the confidentiality and anonymity of the complainant to the fullest
extent possible with an objective to conduct an adequate review. External stakeholders
such as vendors, customers, business partners etc. have the opportunity to submit
‘Complaints’; however, the Company is not obligated to keep ‘Complaints’ from non
employees confidential but will maintain the anonymity of non employees. However we
encourage individuals sending ‘Complaints’ / raising any matter to identify themselves
instead of sending anonymous ‘Complaints’ as it will assist in an effective complaint
review process.

Post review, if the `Complaint’ is found to have been made with mala fide intention,
stringent action will be taken against the complainant. We encourage employees to report
genuine ‘Complaints’ and those submitted in good faith.

4.1        Receipts and treatment of Complaints
(a)        The Manager Security is the primary owner for receipt of all Whistle-Blower incidents.
(b)        Complaints reported are investigated by the Head of Security of each IBU.
(c)        The person/persons against or in relation to whom the `Complaint’ is made shall
cooperate with the Investigator and have the right to provide their inputs during
the investigation.
(d)        A KCM Whistle-Blower e-mail ID will be created and circulated to all employees to
which access will be assigned to the Manager Security and IBU HEAD.
(e)        The IBU HEAD will up-date the status of major Whistle-Blower cases received to the
Group Head of Management Assurance on a monthly basis (through the monthly MIS).
(f)         Where relevant the Whistle-Blower Committee for the IBU related the `Complaint’ shall
sit to investigate the Whistle-Blower incident. The Committee shall comprise the
following members:
• CEO
• IBU HEAD
• Manager Security
(g) At least once in every six months, and whenever else as deemed necessary, the IBU

HEAD shall submit a summarized report to the Audit Committee detailing the following:
•           the Complainant (unless anonymous, in which case the report will so indicate)
•           a description of the substance of the `Complaint’
•           the status of the investigation
•           any conclusions reached by the Investigator
•           findings and recommendations

4.2        Access to Reports and Records and Disclosure of Investigation Results
All reports and records associated with ‘Complaints’ are considered confidential information
and access shall be restricted to the Manager Security and IBU HEAD. ‘Complaints’ and
any resulting investigations, reports or resulting actions will generally not be disclosed to
the public except as required by any legal requirements or regulations or by any corporate
policy in place at that time.

4.3        Retention of Records
All documents relating to such ‘Complaint’s made through the procedures outlined above
shall be retained for at least five years from the date of the ‘Complaint’, after which the
information may be destroyed unless the information may be relevant to any pending or
potential litigation, inquiry, or investigation, in which case the information shall be retained for
the duration of that litigation, inquiry, or investigation and therefore as necessary.

4.4        Amendment to the policy
The Company reserves its right to amend or modify this Policy in whole or in part, at any time
without assigning any reason whatsoever and the same will be posted on the Company
Website.

5.0        Related documents
KCM-P-07 Acceptance of Gifts and Hospitality
KCM-P-24 Code of ethics for employees and code of conduct for contractors

6.0        Amendment register

7.0        Definitions

None