Whistle Blowing Policy

Reportable Incidents

Below is a list of examples (though not exhaustive) of reportable improprieties covered by this policy:

• Corruption
• Bribery
• Fraud
• Unlawful conduct
• Serious conflict of interest without disclosure
• Unethical behaviour or practices
• Breach of organisations policies or code of conduct
• Endangerment to public health or safety or negligence of duty
• Concealing information about any of the above malpractice or misconduct

The Policy DOES NOT apply to the organisation’s policies and procedures for individual employee grievances or complaints relating to terms and conditions of employment; ; recruitment; job performance and appraisal; and, increment, salary adjustment and promotions; which will continue to be administered by the organisation’s Human Resource Department and reviewed by the HR Committee.

Safeguards

All information provided, as well as its source, shall be treated with the strictest confidence. Whistleblowers will be protected from discrimination, retaliation or harassment of any kind for disclosing concerns in good faith.  However, if investigations reveal that a report has been made maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

Procedures

Reports should preferably be made in writing, such as in the form of a letter or email, and in detail setting out the background and history of events, details of parties involved, date or period of time, as well as the reason(s) for concern.  Evidence substantiating the claim, should be provided, where possible.

As concerns or reports made anonymously are more difficult to investigate effectively, contact particulars should be included (in case additional information is required).  This is because the outcome of any investigation conducted into an anonymous report will be subject to the clarity of information provided and limited by the inability to obtain further information from the source of the report.

Handling of complaints

The external party contracted for the purposes of this policy, shall be responsible for maintaining a centralised repository of all reported cases and ensuring that issues raised are investigated and properly resolved. The external party shall be authorised to investigate all reports seriously, confidentially and promptly, and is required to be independent and unbiased in their reporting.

Assessment of the concern or information given, shall be made with due consideration given to the following factors:

• Seriousness of the issue raised;
• Credibility of the concern or information; and
• Likelihood of confirming the concern or information from the source

Depending on the nature of the concern raised or information provided, the investigation will be conducted, using appropriate channels, resources and expertise, and involving one or more of the following individuals or entities:

• The Audit Committee,
• Investigation Team as appointed by the Audit Committee,
• An External Auditor, and/or
• The Police or Commercial Affairs Department.

The amount of contact between the whistleblower and the external party investigating the concern raised or information provided, will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistleblower during the course of the investigation. When the investigation is completed, the external party will report the findings to the Board Chairman and / or Audit Committee for its necessary actions.

Some concerns may be resolved by agreed action without the need for an investigation. This may include general feedback on operational matters which may be forwarded to the respective department head for his/her follow-up.