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Whistle Blowing PolicyDefinition
Whistle Blowing is defined as a deliberate, voluntary disclosure of individual or organizational malpractice by a person who has or has privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing within or by WWPH that is within its ability to control.
This policy applies to all employees of Watt Wah Petroleum Haulage Pte Ltd (WWPH), as well as to all external parties who have business relationships with WWPH. These parties include customers, suppliers, contractors, applicants for employment, and the general public.
The following are some examples of reportable incidents covered by this policy:
1) Accounting & Financial Issues
- Misappropriation of assets or embezzlement
- Bribery, corruption and kickbacks
- Falsification of contracts, reports or official records and documents
- Internal control problems
2) Human Resource Matters
- Workplace retaliation or violence
- Workplace Bullying
- Identity theft
- Security of personal information
- Leaving place of work early without prior approval or constantly reporting late for work
- Absent without notification or valid reasons
3) Ethics & Compliance
- Conflicts of interest
- Violation of the law or company policies
- Misuse of company property
- Managing personal business during working hours and moonlighting
- Vandalism and sabotage
- Ethics violations or misconduct
- Theft, breach of trust of dishonesty in dealing with the company
- Gross negligence or willful deliberate acts resulting in injuring another person or damaging company’s or customer’s property
Protection against Reprisal and Confidentiality
When raising concern or providing information about an actual, suspected, or anticipated wrongdoing, done in good faith; the individual, be it an employee or anyone else, he/she shall be protected against any reprisal such as employment termination, harassment or retribution. All actual, suspected or anticipated wrongdoing as well as its source shall be treated with strictest confidence.
Exceptions to confidentiality:
- When WWPH is under legal obligation to disclose such information provided;
- When the information is already in the public domain;
- When the information is given in strict confidence to legal or auditing;
- Professionals for the purpose of obtaining professional advice; and
- When the information is given to the Police for criminal investigation.
However, WWPH shall not condone any mischievous, frivolous, or malicious allegations. Employees found making such allegations, shall be subject to disciplinary action in accordance to the Employee Handbook on Code of Conduct.
Such complaints/reports may be raised verbally or in writing. The report shall provide as much details and be as specific as possible. These should include details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible. The contact persons to submit such complaint/report are as follows:
1) Mr Danny Lo
Chief Executive Officer
2) Mr Hideki Iwamura
Handling of Reports
The Receiving Officer, may, in consultation with the Board and/or senior management, direct the complaint to the relevant department best placed to address it, or lead the investigation to ensure prompt and appropriate investigation and resolution. All information disclosed during the course of investigation will remain confidential except as necessary or appropriate to take any remedial action, in accordance with any applicable laws and regulations.
The company reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including immediate dismissal.If at the conclusion of an investigation, the company determines that a violation has occurred or the allegations are substantiated, effective remedial action commensurate with the severity of the offence will be taken.