Whistle Blowing Policy

Whistle Blowing Policy and Procedures

  1. The Board of Directors of the Group has put in place arrangements by which all employees of the Group and any other person may, in complete confidence, bring to the attention of Board of Directors, either through the Audit Committee (AC) or the Group Internal Audit Function about actual or suspected improprieties of Senior Managers in the Group.

    As employees are usually the first to know when an improper or illegal act is committed, they are encouraged to bring to the attention of the Board of Directors, any matter which they consider improper or illegal.

    Complainants are encouraged to voice their concerns or complaints in confidence according to the procedures established herein if they become aware of or believe that any of the following activity is taking place in any of the companies in the Group:

    • Fraud, embezzlement of funds or misappropriation of funds or assets.
    • Unethical and improper practices or alleged wrongful conduct relating to the integrity of the financial reporting process, financial records and statements.
    • Questionable, suspicious procedures, deliberate deficiencies, errors or non-compliance on matters relating to accounting, auditing and internal controls.
    • Fraud against investors or authorities.
    • Other acts of corruption, bribery, blackmail and malpractice in the conduct of business.
    • Failure to comply with legal obligations, miscarriage of justice, and criminal offences.
    • Endangering the health and safety of an individual.
    • Any action which is intended to conceal any of the above.
  2. Complainants may report the suspected or actual illegal acts to any of the following:

    Name Designation Email address Postal address
    N. Subramaniam Chairman, Board of Directors and Chairman, Audit Committee
    (This is a dedicated private email which is accessible only by the AC, the whistleblowing letter received will be automatically sent to the AC members.)
    c/o 20 Upper Circular Road, #03-06 the Riverwalk, Singapore 058416.
    Y. C. Lee Member, Audit Committee
    Dileep Nair Member, Audit Committee

    In addition, complaints may also be sent:

    (a) In writing, to a dedicated Post Box Number 96907 at TST P.O., Hong Kong addressed to Internal Audit Department. The post box is maintained exclusively for this purpose.

    (b) In writing, by email to a dedicated email address groupinternalauditor@tchk.com.hk. This email is maintained exclusively for this purpose.

    Employees may submit an anonymous report if they wish to do so. If the employee provides his name, his identity will be treated in strict confidence and will not be disclosed to anyone including Board Members without his consent. However, if the employee remains anonymous, it would not be possible to advise the employee of the actions taken.

  3. The Group shall not permit any form of intimidation or retaliation against an employee by way of, but not limited to, discharge, demotion, suspension, threats, harassment or any other manner of discrimination with respect to an employee's terms or conditions of employment. In respect of an employee who reports a suspected violation in good faith and is not engaged in questionable conduct, the Group will attempt to keep its discussions and actions confidential to the greatest extent possible. In the course of investigation, the Group may need to share information with others on a "need to know" basis.

  4. The action taken will depend on the nature of the items inquiry. Initial inquiries will be made in respect of all reports received (including anonymous reports), to determine the nature and extent of further investigation.

  5. In case where a complainant decides to provide his name, a follow up report will be provided to the complainant after the initial enquiry. If an investigation is done, a summary of the findings of the investigation will be given to the complainant.

  6. The Audit Committee of Thakral Corporation Ltd's Board will exercise the oversight function over the administration of the policy.