INTEGRITY PLEDGE & WHISTLEBLOWER PROTECTION
MANAGEMENT POLICY GUIDELINES 2024-02 | UPDATED AS OF FEB. 29, 2023
1. PURPOSE
We are committed to maintaining the highest standards of integrity, transparency, and ethical conduct. Our people and stakeholders play a crucial role in upholding these principles. This Integrity Pledge and Whistleblower Policy aims to enable everyone to contribute to a culture of trust, accountability, and ethical behavior by –
(a) Encouraging employees, stakeholders, and other relevant parties to report any violations of policies, procedures, or applicable laws.
(b) Providing clear guidelines for reporting any violations or irregularities within our organization.
(c) Providing confidential reporting channels for whistleblowers.
(d) Ensuring that whistleblowers are protected from retaliation.
2. DEFINITIONS
(a) Whistleblower: Any individual who reports suspected misconduct, irregularities, or violations.
(b) Reporting Line: Designated contacts within the organization responsible for receiving and investigating whistleblowing reports.
3. CORE PRINCIPLES
(c) Gifts, entertainment, and hospitality must be transparent, reasonable, and in compliance with Company policies.
(b) Employees must report any suspicious transactions promptly to the General Counsel as the designated AML officer.
4. REPORTING VIOLATIONS
Employees, officers, clients, suppliers, and other stakeholders can report violations, including but not limited to:
- Fraud
- Sexual harassment
- Theft
- Conflict of interest
- Information security breaches
- Violations of company policies, rules, and regulations
- Bribery and Corruption: Any attempt to offer, give, receive, or solicit anything of value to influence business decisions improperly.
5. REPORTING CHANNELS
Whistleblowers may approach any of the following designated contacts:
(a) Head of the People and Culture Office
(b) Chairperson of the Disciplinary Committee
(c) Chairperson of the Internal Quality Auditor
(d) Chief Operations Officer
(e) General Counsel
Under extraordinary circumstances, whistleblowers may also report directly to the President or any Board Member.
6. CONFIDENTIALITY AND PROTECTION
6.1 Confidentiality
(a) The identity of the whistleblower will be kept strictly confidential.
(b) The subject matter of the disclosure will also remain confidential.
6.2 Protection
(a) We will take measures to ensure the well-being of the whistleblower.
(b) Retaliation against whistleblowers is strictly prohibited.
7. REPORTING METHODS
Whistleblowers can report violations formally or anonymously through:
- Face-to-face meetings with designated contacts
- Written communication (via email or internal channels)
- External email: [email protected] (shared inbox managed by the CEO, CAFO, COO, and HR)
8. INVESTIGATION PROCESS
Upon receiving a whistleblowing report, the designated personnel will:
8.1 Initiate an investigation by gathering relevant details and documents.
8.2 Follow due process as stipulated in the procedural guidelines for disciplinary cases.
9. GOOD FAITH REPORTING
We presume that whistleblowers act in good faith and will not make false accusations. Any knowingly false statements may result in disciplinary action, including termination.
10. EFFECTIVITY
This policy shall have retroactive effect and supersedes any prior policies.
