WHISTLEBLOWING POLICY
1. Purpose
1.1 This Policy aims to:
- Encourage business associates (including but not limited to customers and suppliers) and employees of the Group to report any suspected misconduct, malpractice or wrongdoing (including actual or suspected violations of the Group’s code and policies or any applicable law or regulations) as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
- Provide reliable avenues for whistleblowers to raise concerns.
- Provide guidance and procedures to facilitate independent investigation of the reported concern and for appropriate follow up actions to be taken.
- Allow the Group’s directors and management (other than the subject of the whistleblowing) to be informed at an early stage about acts of misconduct, malpractice or wrongdoing.
- Provide assurance to whistleblowers that they can raise their concerns in good faith without fear of reprisals.
- Foster a culture of accountability and integrity.
1.2 The Company’s Audit Committee (the “Audit Committee”) shall be responsible for oversight and monitoring of any whistleblowing matters (including any amendments to this Policy).
2. WHAT TO REPORT
2.1 You are encouraged to come forward to report any reasonable concern of misconduct, malpractice or wrongdoing that comes to your attention, including but not limited to the following:
- Criminal activity/offences and miscarriages of justice.
- Endangerment to health and safety of an individual or an asset.
- Damage caused to the Group’s assets or to the environment.
- Breach of legal or regulatory requirements.
- Acts of bribery and corrupt practices.
- Acts of theft.
- Financial fraud or mismanagement.
- Gross negligence leading to a material loss or damage to the Group.
- Sexual harassment.
- Discrimination on grounds of race, age, sex or disability.
- Violation of the Group’s code and policies (including procedures).
- Improper or unethical conduct that may damage the Group’s reputation.
- Unauthorised disclosure of confidential information.
- Deliberate concealment of any of the above matters.
2.2 Personal grievances and complaints, customer service complaints as well as personal disputes are not covered under this Policy.
3. REPORTING A CONCERN
3.1. Whistleblowers may report whistleblowing concerns through the following channels:
- Place a written complaint in a sealed envelope, marked “Private and Strictly Confidential – Attention: Audit Committee Chairman” and sent to “AsiaMedic Limited, 350 Orchard Road #10-01, Shaw House, Singapore 238868”. The envelope shall be forwarded unopened to the Audit Committee Chairman;
- Email the complaint to whistleblow@asiamedic.com.sg with the subject header “Private and Strictly Confidential – Attention: Audit Committee Chairman”. The email will be routed to Audit Committee Chairman; or
- Call Mr Stanley Woo at 6505 6091 or Ms Jacqueline Chew at 6505 6086.
For proper documentation and records, whistleblowers are encouraged to submit their concern via email or mail.
3.2 All the whistleblowing concern received will be submitted to the Audit Committee.
3.3 Whistleblowers are strongly encouraged to identify themselves when reporting a concern so that appropriate follow-up questions and investigations can be conducted. Concerns expressed anonymously may be investigated after given due consideration to the following:
- Seriousness of the concern.
- Credibility of the concern raised.
- Likelihood of confirming the allegation from other credible sources.
3.4 The Company is committed to ensure protection of the whistleblower against detrimental or unfair treatment. Disciplinary action (including dismissal) shall be taken against any person who:
- Attempts to impede, prevent, or obstruct a whistleblowing concern from being made or an investigation from being carried out.
- Harass or victimise the whistleblower or subject the whistleblower to detrimental or unfair treatment.
4. HANDLING A REPORTABLE CONCERN
4.1. The Company will undertake each case with impartiality, fairness and confidentiality.
4.2. The identity of the whistleblower will be kept confidential, with disclosure on a need-to-know basis to the following:
- the Audit Committee;
- the investigating team;
- the Board of Directors of the Company; and
- any party to whom the identity of the whistleblower is required to be disclosed by law