Whistleblowing Policy Statement
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Policy Statement
This Whistleblowing Policy establishes a formal, secure channel for all stakeholders (employees, contractors, and partners) to report misconduct. Reports made in good faith are protected from any form of retaliation. -
Scope of Improper Conduct
This Policy applies to all directors, employees, and "Associates" (contractors, suppliers, and stakeholders). Improper conduct includes, but is not limited to:- Any unlawful or illegal activity, whether criminal or a breach of civil law;
- Breaches of the Group's policies and procedures;
- Misuse or misappropriation of the Group's funds, assets, or resources;
- Bribery, corruption or blackmail;
- Criminal breach of trust and/or abuse of power and position;
- Conflict of interest;
- Unsafe working conditions;
- Insider trading;
- Misuse of confidential information;
- Discrimination, harassment or abuse;
- Improprieties and irregularities in accounting and financial reporting; and
- Concealment or deliberate suppression of any of the above matters or any other acts of wrongdoing.
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Procedure in Making a Disclosure
- Channels: Disclosures can be made via email (compliance@asmechholdings.com).
- Anonymity: Reports can be submitted anonymously, though whistleblowers are encouraged to provide contact details to help with further inquiries.
- Content of Report: A whistleblowing report should include the individual's identity (unless reporting anonymously), a thorough description of the incident, and any available documentary evidence to substantiate the claim.
- Investigation Timeline: The process involves a 14 working days preliminary assessment to determine merit, followed by a 14 working days detailed investigation for substantiated claims.
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Protection and Confidentiality
- Non-Retaliation Guarantee: The Company strictly prohibits any form of harassment, discrimination, or career-related retaliation against whistleblowers who report in good faith.
- Disciplinary Action: Any act of retaliation against a whistleblower is considered a serious offence and will result in disciplinary measures.
- Legal Rights: These internal protections do not override or limit the legal rights provided under the Whistleblower Protection Act 2010 or other relevant laws.
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Reporting to Authorities section:
Full Cooperation: In cases involving legal or regulatory violations, the Company will fully assist government enforcement agencies in any jurisdiction where the Group operates. -
Record Safekeeping
All whistleblowing reports and investigation records must be securely documented and stored for at least seven years, with access strictly limited to authorized personnel. -
Policy Review
The policy will be reviewed at least once every three years to ensure ongoing effectiveness and alignment with evolving laws and the business environment.