1.1 This Policy aims to:
(a) 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.
(b) Provide reliable avenues for whistleblowers to raise concerns.
(c) Provide guidance and procedures to facilitate independent investigation of the reported concern and for appropriate follow up actions to be taken.
(d) 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.
(e) Provide assurance to whistleblowers that they can raise their concerns in good faith without fear of reprisals.
(f) 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:
(a) Criminal activity/offences and miscarriages of justice.
(b) Endangerment to health and safety of an individual or an asset.
(c) Damage caused to the Group’s assets or to the environment.
(d) Breach of legal or regulatory requirements.
(e) Acts of bribery and corrupt practices.
(f) Acts of theft.
(g) Financial fraud or mismanagement.
(h) Gross negligence leading to a material loss or damage to the Group.
(i) Sexual harassment.
(j) Discrimination on grounds of race, age, sex or disability.
(k) Violation of the Group’s code and policies (including procedures).
(l) Improper or unethical conduct that may damage the Group’s reputation.’
(m) Unauthorised disclosure of confidential information.
(n) 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 firstname.lastname@example.org 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:
(a) Seriousness of the concern.
(b) Credibility of the concern raised.
(c) 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:
(a) Attempts to impede, prevent, or obstruct a whistleblowing concern from being made or an investigation from being carried out.
(b) 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:
(a) the Audit Committee;
(b) the investigating team;
(c) the Board of Directors of the Company; and
(d) any party to whom the identity of the whistleblower is required to be disclosed by law
4.3. The whistleblower’s consent will be obtained prior to disclosing his/her identity to anyone other than in those identified above.
4.4 All whistleblowing matters shall be properly documented and filed. Whistleblowing concern reported though a phone call shall be logged by the receiver and emailed to the Audit Committee for documentation purposes.
4.5 Upon receipt of the whistleblowing concern, the Audit Committee will carry out an initial assessment to determine if an investigation is required and the scope of the investigation.
4.6 If the whistleblowing concern involves a member of the Audit Committee, the Audit Committee member shall abstain from participating in the investigation or discussion so that the concern may be investigated independently.
4.7 The Audit Committee shall nominate an independent investigation team to conduct the investigation. All members of the investigation team shall be independent of the whistleblowing concern and conduct the investigation impartially.
4.8 The investigation team may contact the whistleblower and any party deemed relevant by the investigation team for further information to conduct its investigation. Individuals who are interviewed or asked to provide information are obliged to fully cooperate with the investigation team and must refrain from discussing or disclosing matters concerning the investigations.
4.9 Depending on the nature of the concern raised or information provided, the investigation team (at the consent of the Audit Committee) may consult external and/or internal auditors, private investigators or specialist/experts with relevant knowledge or experience to assist with the investigation.
4.10 The investigation team is expected to handle all matters seriously, confidentially and promptly. An investigation report, remedial actions and recommendation of improvement to the Group’s policies and procedures to prevent future misconduct, malpractice or wrongdoing, if any, shall be submitted by the investigation team to the Audit Committee for review within four (4) weeks (or longer as approved by the Audit Committee) from the forming of the investigation team.
4.11 Based on the outcome of the investigation, the Audit Committee shall determine the appropriate actions to address and rectify the whistleblowing concern, including but not limited to dismissal or referring to the relevant law enforcement authority, if required. All actions shall be tabled to the Board of Directors for approval before implementation.
4.12 Investigation results are confidential and will not be disclosed or discussed with anyone other than those with a legitimate need to know. While the whistleblower will be informed of the outcome, the whistleblower shall not be entitled to the information or reports collated by the investigation team in the course of the investigation.
4.13 If the investigation concludes that a whistleblower has made false allegations maliciously, in bad faith or with a view to personal gain, the whistleblower may be subject to applicable legal action or internal disciplinary actions.
4.14 The Company will make periodic whistleblowing reports at its board meetings. A “NIL” report is required if there is no whistleblowing event during the reported period.
5. External Disclosures
5.1 The Company shall not, except in the course of duty or under compulsion by law or SGX-ST rules, disclose, divulge or make public any information of a confidential nature relating to the details of the alleged misconduct, malpractice or wrongdoing. The Company shall ensure that the identity of the whistleblower is kept confidential.
This Whistleblowing Policy (this “Policy”) is last updated on 16 December 2021.