To ensure that all employees, clients or any other individual or organisation that deals with the Company has an effective channel to report non-compliance with the Company’s Code of Ethics without fear of retaliation, this policy provides a process for the anonymous submission of suspected wrongdoing (whistle blowing) by any employee of the Company. It is the policy of the Company to treat complaints about the Company’s financial affairs, internal accounting controls, auditing or operational matters or activities that are considered serious improper conduct (“Complaints”) seriously and expeditiously.
The Company will abide by all laws that prohibit retaliation against employees who lawfully submit Complaints under this policy and procedures.
The responsibility for receiving Complaints rests with the Company’s Audit Committee of the Board of Directors. The Audit Committee and the Company are responsible for the periodic review and update of this Policy.
3.1 Scope of the Policy and Procedures
This document describes the procedures that should be followed to report non-compliance with the Company’s Code of Ethics. Any allegations raised under these procedures should be submitted to the Company’s Ethics email email@example.com.
An individual (“the Whistle Blower”) will be given the opportunity to submit an anonymous and confidential Complaint to the Audit Committee for review by the Company. The report may cover any suspected events that employees or clients or others consider to be breaches of the Company’s Code of Ethics, including matters related to the Company’s financial affairs, internal accounting controls, auditing or operational matters or activities that are considered serious improper conduct.
Complaints may be reported anonymously, on the option of the Whistle Blower. The Company shall maintain the confidentiality or anonymity of the person(s) making the Complaint to the extent that this is reasonably practicable considering the requirements of the law and the need to conduct further investigations. Legal or business requirements may not allow for complete anonymity. Also, in some cases it may not be possible to proceed with or properly investigate the matter unless the complainant identifies himself or herself.
In general, it is less likely that an investigation will be initiated in response to an anonymous Complaint due to the difficulty of interviewing anonymous complainants and evaluating the credibility of their Complaints. In addition, persons making Complaints should be aware that their identity might become known for reasons outside the control of the Company. The identity of other persons subject to or participating in any inquiry or investigation relating to a Complaint shall be maintained in confidence subject to the same limitations.
Retaliation against a Whistle Blower who, in good faith, has made a Complaint, disclosed information relating to a Complaint or otherwise participated in an investigation relating to a Complaint, is prohibited regardless of the outcome of the investigation. The Company shall not dismiss, demote, suspend, threaten, harass or in any manner discriminate against an employee in the terms and conditions of employment based upon any lawful actions of such employee with respect to good faith reporting of Complaints or participation in a related investigation. An employee’s right to protection from retaliation, however, does not extend immunity for any complicity in the matters that are the subject of the Complaint or an ensuing investigation.
Deliberately making a false report is also against this policy. This is not meant to discourage or limit the rights of individuals from making reports of alleged violations of the Company’s Code of Ethics or any other approved policy. The Company recognises that, in some instances, it may not be possible to determine whether a report is warranted. Individuals should not be reluctant to report information because they are uncertain of who will be believed and whether the allegation can be proved.
This Policy and Procedures are available on the Company’s website under “Policies”.