Whistleblowing & Compliant Policies (“Policy”)
1. Objective & Scope
- establish a strong whistleblowing framework for employees, customers, and any stakeholders/persons providing goods and services to the Company to report serious concerns and possible corporate improprieties related to fraud, misconduct, governance or ethics;
- ensure that reliable arrangements are in place to facilitate independent investigations of the reported concerns and for proper follow-up actions.
This policy does not apply to grievances concerning one’s employment terms or an employee’s performance matters since these matters are to be dealt under a separate policy governing Human Resource issues.
The Company is fully committed to maintaining high standards of compliance with accounting, financial reporting, internal controls and auditing requirements and any legislation related thereto. As such, the captioned Policy strives to provide a trusted channel for the employees/external parties to lodge the abovementioned concerns in confidence.
No employee shall use his/her position to prevent other employees from complying with their obligations as indicated in this Policy, of which conforms with the guidelines set out in the Code of Corporate Governance.
The Policy applies to the Company and its related companies (“the Company”), and its employees, and any other persons or business organisations carrying out work for them.
3. What is “Whistleblowing”
“Whistleblowing” is defined as “a voluntary disclosure or reporting of an individual or organizational misconduct by a person who has or has had access to data, events or information about an actual or anticipated wrongdoing within, or by members of the Company based on his or her reasonable and honest belief.
4. Reportable Incidents
Reportable suspected wrongdoings include but are not limited to:
(a) misconduct relating to financial reporting, accounting or other financial matters;
(b) corruption, misappropriation or blackmail;
(c) conduct which is an offence or breach of law;
(d) significant breach of the Company policies or internal controls;
(e) endangerment of the health and safety of an individual;
(f) any other serious improper matters which may cause financial or nonfinancial loss to the Company, or damage to the Company’s reputation or
(g) concealment of any of the above
All reports of incidents, including information or evidence provided, on matters relating to whistleblowing will be handled with strictest confidentially, except as necessary/appropriate to conduct investigations and to take remedial actions, in accordance with the appliable laws and regulations;
The identity of the individual making the allegation (“Whistleblower”) shall be kept confidential so long as it does not obstruct or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.
6. Protection Against Reprisals (Retaliations)
The Company prohibits harassment or victimization of any kind against a Whistleblower who submits a report in good faith;
No one should suffer reprisal as a result of reporting a genuine concern, even if they turn out to be mistake;
While the Policy is meant to protect the Whistleblower from any unfair treatment as a result of their report, the Company does not condone any frivolous or malicious allegations. Likewise, if investigations reveal that that the Whistleblower making the allegation had done so maliciously for personal gain, appropriate action may be taken in accordance with the law
7. Whistleblowing Communication Channels
8. How to make a report
All concerns raised will be independently reviewed to ensure that they are fairly and properly considered.
As it is essential to have all critical information in order to be able to effectively evaluate and investigate a case, the report should be submitted in writing, detailing out the chronological events and also providing areas of concerns. In short, to provide as much information and be as specific as possible.
Concerns conveyed anonymously are difficult to justify and may hinder investigation. Accordingly, the Company will consider and decide if anonymous reports should be further investigated based on the individual merit of each circumstance. Hence, the whistleblower is encouraged to provide their contact details so that clarifications could be sought during the course of investigation. If a whistleblower chooses to make such reports anonymously, he/she shall not be entitled to the investigation outcome of the case reported.
9. Policy Review
The Policy shall be reviewed annually, where the Policy may be modified, to maintain compliance with applicable laws and regulations or accommodate organisational changes.
This annual review shall be carried out by Internal Audit or Independent party. Any changes will be subjected to the approval of the Audit Committee.
Last Updated: 31 Oct 2023