Whistle Blowing Policy
1. Whistle-blowing Policy Introduction
We are fully committed to conducting business with integrity and consistent with the highest ethical standards, and compliance with all applicable laws and regulatory requirements. The Company strongly believes that the actions and conduct of all employees of the Group, as well as other persons acting on behalf of the Company and/or its subsidiaries, are essential to maintaining these standards. In line with this commitment and the Code of Corporate Governance, we adopted this Whistle-blowing Policy to ensure necessary arrangements are available.
The Audit Committee of the Company shall have the overall authority and oversight of this Policy from time to time and may in its absolute discretion delegate the investigation of the whistle-blowing reports and implementation of this Policy to such person as it deems fit.
2. Whistle-blowing Reporting/Communication Channels
This Policy applies to any suspected improprieties involving employees as well as consultants, vendors, contractors, and/or any other parties with a business relationship with the Company.
In line with this commitment, dedicated communication channels have been established and whistle-blowers may choose to use any of these communication channels. The available communication channels are as follows:
By Post: 13/F., Amber Commercial Building
70 Morrison Hill Road
You may be directly reported to Mr. Edwin Chiu, the Chairman of the Audit Committee. The above communication channels are secure and all information received will be treated with the utmost confidentiality.
3. How to Make a Report
When making a report, the whistle-blower should as far as possible include the following information:
Date, time and place of the actions/transactions
Identity and particulars of parties involved
Circumstances leading to the improprieties
Any other relevant information or documentation that would assist in the evaluation of the report.
4. How will the Company Respond
Harassment or Retaliation: The Company recognizes that the decision to report a concern can be a difficult one to make, not least because of the fear of reprisal from those responsible for the malpractice or improprieties. The Company will not tolerate harassment or victimization and will take reasonable and appropriate action to protect you when you raise a concern in good faith.
Confidentiality: The Company will do its best to protect your identity when you raise a concern and do not want your identity to be disclosed. It must be appreciated though that the investigation process may need to reveal the source of information and the report made by you may be required as part of evidence.
Anonymous Report: The Company strongly encourages you to put your name to your report. The Company is committed to protecting whistle-blowers who make reports under this policy. Subsequent investigation may be hindered if contact cannot be made with the whistle-blower to obtain clarification or further information. The Company is committed to respect the rights of all of its employees/whistle-blowers, which include the right of an accused person, in due course, to know the identity of his or her accuser. The identity would, however, not be disclosed unless it is absolutely necessary for the purpose of the investigation and/or subsequent action, and never disclosed without prior discussion with the whistle-blower making the report.
5. Scope of Improprieties
Possible improprieties which should be reported pursuant to this Policy may include but are not limited to the following:
Any fraudulent act or forgery
Misappropriation of funds or assets
Profiteering as result of insider knowledge of the Company’s activities/information
Disclosing confidential or proprietary information to external parties
Accepting or seeking anything of material value from vendors, contractors or any persons providing goods and/or services to the Company
Destruction/removal/inappropriate use of Company’s records/assets/ facilities
Violation of existing legislation, rules and regulations applicable to the Company relating to its accounting, financial reporting, internal controls and/or policies
Improper actions or omissions which are likely to endanger the Company’s employees, customers and/or members of the public
Distinct effort to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external auditor/accountant in connection with the preparation, examination, audit or review of any financial statements or records of the Company