1.0 SCOPE AND APPLICATION
This Policy provides a system that enables our company’s Employees and Stakeholders acting in good faith to raise concerns and disclose actual or potential wrongdoings or misconduct in our company. These wrongdoings or misconduct include but are not limited to:
- Violation of laws and regulations.
- Unethical behaviour or breach of Code of Conduct.
- Giving, solicitation or acceptance of bribes.
- Acts that adversely affect the interests or values of shareholders and Stakeholders.
- Unauthorized disclosure or sale of company information.
- Falsification of reports or documents
- Fraud, theft, embezzlement, or misuse of company assets.
- Improper or undesirable personal behaviour or misdeeds which seriously impacts our company’s business or reputation.
- Sexual or other forms of harassment in the workplace; and (x) attempts to cover any of the aforementioned.
Employees and Stakeholders who raise their concerns in good faith in accordance with this Policy are protected from reprisals within the limits of the law and assured that all reported cases will be objectively investigated on a best effort basis and appropriate remedial measures taken where warranted.
This Policy is not intended to restrict or otherwise govern legal rights and obligations which Employees and Stakeholder have, or may have, in relation to the subject matter of the whistleblowing report.
This Policy is not intended for Employees to lodge Employee Grievances or appeal on disciplinary procedures. Employees can report Employee Grievances or lodge appeals on disciplinary procedures through our company’s human resources department.
Employees and Stakeholders should exercise due care to ensure that the information in their whistleblowing report is accurate and truthful. No action will be taken against Employees or Stakeholders who make an allegation in good faith which is not confirmed by subsequent investigation. But this protection may be revoked if Employees and Stakeholders misuse or abuse the Whistleblower Policy by making false, frivolous, malicious, or vexatious allegations.
2.0 HOW TO MAKE A WHISTLE BLOWING REPORT
Employees and Stakeholders should report their concern at the earliest opportunity so that corrective action can be taken as soon as possible.
The monitoring and execution of this Whistleblowing Policy will be placed under the supervision of the Whistleblowing Committee comprising of Managing and Operating Directors of our company.
The Director shall be the chair for the meeting of the Whistleblowing Committee where a quorum of no less than two (2) members are present and, in his absence, another member of the Audit Committee shall be the chair.
Where any member of the Whistleblowing Committee is the subject of the investigation, the member will be reclused from attending any meeting of the Committee.
Employees and Stakeholders have the option to make whistleblowing reports in strict confidence through any of the following channels:
Reports may be made on an anonymous basis. However, natural justice usually requires that the details and identity of the Employee or Stakeholder submitting the whistleblowing report be disclosed in any disciplinary investigation or action to be taken against the person(s) who is a subject of the complaint in the whistleblowing report. Anonymous whistleblowing reports will therefore be considered at the discretion of the Whistleblowing Committee. In exercising this discretion, the Whistleblowing Committee will consider
- The seriousness of the issues raised.
- Credibility of the whistleblowing report, and
- Likelihood of confirming the allegation from the relevant sources.
Whistleblowing reports should include the following disclosures:
- Background and history of the concern (giving relevant dates).
- Reason for the concern, and
- Identity of the person(s) committing the alleged wrongdoing. Insufficient details in the whistleblowing report may impede the investigation and resolution of the concerns raised.
3.0 CONFIDENTIALITY AND SAFEGUARDS
All whistleblowing reports will be treated as confidential to the extent reasonably practicable. The identity of the Employee or Stakeholder who submitted the whistleblowing report may be kept confidential so long as it does not impede or frustrate investigation. The investigation process may also reveal the source of the information and the Employee or Stakeholder who raised the concern may be required to provide a statement as part of the evidence.
This Whistleblowing Policy offers protection within limits of the law and to the extent reasonably practicable to Employees and Stakeholders who submit whistleblowing reports internally in good faith, even if the allegations prove to be unfounded or mistaken. These Employees and Stakeholders will be appropriately protected from internal disciplinary actions (if applicable), dismissal, harassment, victimization, or informal pressures. No protection from internal disciplinary action will be offered if Employees do not adhere to the procedures for whistleblowing and disclosures in this Policy.