Objective
To encourage employees, customers, and all external parties to comply with applicable laws, regulations, policies, and rules, and to provide a channel for reporting any acts that are believed to be in violation of such requirements or standards of information disclosure.
Scope of Whistleblowing
1. Suspicious behavior related to illegal activities, including corruption and bribery.
2. Violations of company policies.
3. Business conduct that breaches the companys internal regulations or official laws and regulations.
4. Suspicious behavior involving material accounting or auditing matters.
5. Any actions that are unethical or contrary to principles of social justice.
Procedures
Employees, customers, or external individuals (whistleblowers) who witness or become aware of any incidents that fall within the scope described above may file a report, along with credible information and sufficient detail to allow for proper investigation.
The whistleblower may choose to disclose their identity or remain anonymous. The report must be submitted in writing and sent to both the Chairman of the Board and the Chairman of the Audit Committee via one of the following channels:
1) Postal Mail
2) Email
3) Company Website [Insert Company Website Here]
The company will treat whistleblowers fairly and without prejudice. If the whistleblower is an employee, the company will not take any unfair actions such as reassignment, relocation, suspension, intimidation, harassment, termination, or any other form of unfair treatment as a result of the report.
If the whistleblower is a customer or external party, the company will handle the report with transparency and treat all stakeholders equally and fairly, in order to build trust and confidence in the integrity of the investigation process.
Whistleblowers who do not act in good faith and/or are found to have intentionally submitted false or malicious reports that cause harm to the company will face consequences. If the individual is an employee, disciplinary action will be taken in accordance with the companys work regulations. If the whistleblower is a customer or external party and the report causes damage to the company, legal action may be pursued.
The company will maintain confidentiality of all related information, including the whistleblowers identity and the content of the report, unless additional information is legally requested or disclosure is required by law. In such cases, the company will inform the whistleblower prior to any disclosure.
The whistleblower recipient will assess whether the reported matter requires further investigation, taking into account principles of fairness and integrity. If an investigation is deemed necessary, the whistleblower will be informedexcept in cases where the report was submitted anonymously.
If an investigation is to proceed, a fact-finding committee shall be appointed. The committee will be chaired by one representative from the Audit Committee and will include senior management members from relevant departments who are not involved or conflicted in the matter under investigation, as deemed appropriate by the chairperson of the investigation committee.
If the investigation confirms the reported misconduct, the company will promptly implement corrective and preventive measures. If necessary, disciplinary action will be taken against the responsible individuals or the matter may be reported to the appropriate regulatory authorities.
All information provided by the whistleblower, along with any evidence or investigation findings, will be treated as confidential documents and securely kept by the Secretary of the Audit Committee.
This Whistleblowing Policy is effective as of February 21, 2020, and shall be publicly announced to employees and external stakeholders via internal notice postings.