Hanwell Holdings Limited Whistleblowing policy (“WBP”)
The WBP governs the receipt, retention and treatment of someone (“Whistleblower”) who raises concern about possible unethical or fraudulent practices or wrongdoings at work place (“Alleged Wrongful Act”) that may result in either financial or reputational loss, both actual or potentially detrimental to HANWELL HOLDINGS LIMITED (the “Company”) and its subsidiaries (the “Group”). It provides not only a policy to enable the Alleged Wrongful Act to be reported but also safeguards to minimize the abuse of whistleblowing that may be false, frivolous or malicious.
The Group is committed to the highest possible standards of corporate governance and this policy aims to provide an avenue for the Whistleblower who may be an employee or external party to come forward to report an Alleged Wrongful Act without fear or favour.
The WBP allows the Whistleblower to report an Alleged Wrongful Act in relation to breaches or non-compliance of:
3.1 applicable laws, regulations or rules that may have negative or significant impact to the Group’s reputation and/or performance;
3.2 reliable and truthful financial reporting;
3.3 work place policies of the Group including adequacy and effectiveness of systems of internal controls addressing (financial, operational, compliance and information technology risks) and risk management systems;
3.4 measures that safeguard the assets and resources of the Group; and
3.5 fair treatment to all staff, especially with regard to health and safety issues.
The WBP shall be read in conjunction with all applicable laws regulations, rules, codes, directives, guidelines and standards issued by relevant authorities and government agencies where the Group has operations, business activities and workplace policies.
The Company does not tolerate any retaliation against an employee who whistleblows in good faith. Examples of retaliation may include dismissal, demotion and personal attacks. Retaliation also includes subtle actions such as avoiding or ostracizing; leaving him or her out of professional or social activities and so on. Retaliation can be a ground for disciplinary action in such situations.
However, an employee who knowingly makes an allegation that is false, frivolous or malicious will be in violation of the WBP and will be subject to disciplinary action in accordance with the law and/or workplace policies of the Group. Likewise, if investigations reveal that an external party making an allegation through the whistleblowing channel in bad faith or for personal gain, the Company reserves the right to refer the matter to the relevant authorities.
Every reasonable effort will be made to protect the Whistleblower’s identity, if so requested and, provided always that it is compatible with proper investigation. However, it is important to be aware that it may be necessary to reveal the identity of the Whistleblower to assist in an investigation where:-
5.1 the law requires; or
5.2 information is already in the public domain; or
5.3 information is given on a strictly confidential basis to external advisers who have been engaged by the Group to assist in the investigation of the Alleged Wrongful Act; or
5.4 information is disclosed to the relevant authorities for investigation.
6.0 Anonymous Allegations
The WBP encourages the Whistleblower to identify himself/herself when reporting an Alleged Wrongful Act so that timely investigation can be carried out. Concerns expressed anonymously will be investigated, but consideration will be given to the:
6.1 severity of the issue(s);
6.2 credibility of the concern; and
6.3 likelihood of securing confirmation from attributable sources,
in relation to the Alleged Wrongful Act.
7.0 Reporting Mechanism
All whistleblowing cases should be reported to the Chairman of the Audit Committee who is assisted by two independent Whistleblowing Investigation Officers appointed by the Audit Committee, through the following channel:
By hand or by registered post under a sealed envelope to be addressed to:
Chairman of the Audit Committee, Hanwell Holdings Limited
c/o Whistleblowing Investigation Officers
348 Jalan Boon Lay
The Company may modify the WBP to maintain compliance with applicable laws and regulations or aligning to the provisions of the Code of Corporate Governance and the Listing Rules of the Singapore Exchange Securities Trading Limited as and when required.
9.0 Dissemination of WBP
A copy of the WBP and any subsequent modification thereof shall be made known to all the directors, officers and employees including publicly disclosing the WBP on the Company’s corporate website.
10.0 Maintenance of the WBP
The Audit Committee is responsible for the maintenance, review and updating of the WBP. Any such revision or addendum to this policy can only be implemented after securing the approval of the Audit Committee.
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