Whistleblowing is the confidential disclosure by an individual of any concern encountered in a workplace relating to a perceived wrongdoing. “Whistleblower” is defined by this policy as an Employee or contractor who reports, to one or more of the parties specified in this Policy, an activity that he/she considers to be illegal, dishonest, unethical, or otherwise improper.
The Company considers such wrongdoing to include:
a) Fraud (an act of willful misrepresentation which would affect the interests of the concerned) against investors, securities fraud, mail or wire fraud, bank fraud, or fraudulent statements to relevant authority;
b) general malpractice - such as immoral, illegal or unethical conduct;
c) gross misconduct;
d) potential infractions of the Company’s internal controls;
e) potential infractions of the requirements in, or made under, the regulations of the relevant countries where the Company operates;
f) potential infractions of the codes of conduct of all relevant professional institutions; and
g) any other event which would affect the interests of the business.
a) to encourage timely reporting of alleged malpractices/misconduct;
b) to provide a means of discreet and confidential channel for escalation of concerns without fear of reprisal;
c) to ensure consistence and timely responses to reported impropriety and awareness by whistleblowers of their obligations/rights;
d) to serve as a means of preventing and deterring misconduct that may be contemplated but has not yet taken place; and
e) to protect the rights of the Authority and its stakeholders.
2.1 Internal Whistleblowers:
Employees are expected to report incidents of misconduct involving peers, supervisors or senior management to relevant reporting authorities.
2.2 External Whistleblowers:
Clients, customers, service providers and other members of the public who report unethical conduct of Employees to the Managing Director on issues relating to Management and the Human Resource Head on matters relating to all staff.
a) The Whistleblower should promptly report the suspected or actual event to his/her supervisor.
b) If the Whistleblower would be uncomfortable or otherwise reluctant to report to his/her supervisor, then the Whistleblower could report the event to the next highest or another level of management, including to an appropriate Board committee or member.
c) The Whistleblower can report the event with his/her identity or anonymously.
d) The Whistle blower shall receive no retaliation or retribution for a report that was provided in good faith – that was not done primarily with malice to damage another or the organization.
e) A Whistleblower who makes a report that is not done in good faith is subject to disciplinary action, including termination or other legal means to protect the reputation of the organization and members of its Board and staff.
f) Anyone who retaliates against the Whistleblower (who reported an event in good faith) will be subject to discipline, including termination of Board or Employee status.
g) Crimes against persons or property should immediately be reported to the local police department.
h) Supervisors, managers and/or board members who receive the reports must promptly act to investigate and/or resolve the issue.
i) The Whistleblower shall receive an acknowledgement and a plan of action within 7 working days of the initial report, regarding the investigation, disposition or resolution of the issue.
The identity of the Whistleblower, if known, shall remain confidential to those persons directly involved in applying this policy, unless the issue requires investigation by law enforcement, in which case members of the organization are subject to subpoena.
.png)
.png)