Whistleblowing Policy
Commitment
The Company is committed to maintaining the highest standards of conduct and integrity. To this end, the Company encourages its employees and those who deal with it (e.g. customers and suppliers) (“Relevant Parties”) to report concerns about any malpractice and impropriety that come to their attention. This policy aims to assist the employees and Relevant Parties to disclose information which is related to malpractice and impropriety to the senior management of the Company or, if they consider appropriate and desirable, to the Company’s Audit Committee.
Approach
I. Activities to be reported
Malpractice activities may include but not be confined to:
- Breach of legal or regulatory requirements.
- Malpractice, impropriety or fraud relating to financial and other matters which will adversely affect the Company's reputation.
- Violation of codes of conduct and regulations applicable within the company.
II. Communication Channels
For Company’s employees – Employees should first raise any malpractice concerns with their immediate supervisors / department managers. If for any reason, the employees prefer their supervisors / department managers not to be told, they may report their concerns directly to Director of Human Resources, Head of Internal Audit and General Counsel / Company Secretary through phone call or email to [email protected].
For Relevant Parties – Relevant Parties may report their concerns to the Company’s Head of Internal Audit and General Counsel / Company Secretary through email to [email protected].
Employees and Relevant Parties (as the case may be) may choose to (but are not obliged to) provide their names and preferred contact method when raising any malpractice concerns.
Employees and Relevant Parties (as the case may be) may also choose to raise their concerns with the Audit Committee of the Company by requesting the same in their reporting.
All information received would be kept confidential..
III. Investigation Procedures
Unless acknowledgment is not reasonably practicable, all cases received through the whistleblowing channels will be acknowledged. A person will be designated to manage and investigate the case. Unless it is found to be scandalous, frivolous or vexatious after an impartial and comprehensive investigation, the case, investigation outcomes and recommendations, if any, will be reported in a timely manner to:-
- the Chief Executive Officer; and
- the Vice Chairpersons and the Audit Committee of the Company if (i) considered appropriate and necessary or (ii) reporting to the Audit Committee of the Company is requested by the employees and Relevant Parties (as the case may be).
Subject to the nature and complexity of the matter, the employees and Relevant Parties (as the case may be) will be informed of the investigation outcome and actions taken, if any, when the investigation is completed.
IV. Protection and Confidentiality
Employees and Relevant Parties are highly encouraged to report concerns about any malpractice. The importance of whistleblowing in both deterring and detecting malpractice is well recognized by the Company. Employees and Relevant Parties should not suffer any form of intimidation and retaliation because of reporting a concern about any of the above matters. The Company will make every effort to treat all disclosures in a confidential and sensitive manner. Employees and Relevant Parties should also keep the fact that they have filed a report, the nature of their concerns and the identity of those involved confidential.
In making a disclosure, employees should exercise due care to ensure the accuracy of information. Disciplinary actions will be taken against employees who deliberately raise false and malicious allegations.
V. Governance
The Company’s Chief Executive Officer, Director of Human Resources, Head of Internal Audit and General Counsel / Company Secretary are responsible for reviewing Company’s whistleblowing procedures and receive regular updates on relevant matters of concern raised under these arrangements, together with any management actions taken in response.