Whistle Blowing Policy

Content

INTRODUCTION

PURPOSE

SCOPE

Compliant Management

RESPONSIBILITIES

DEFINITIONS

APPLICABILITY

REPORTABLE ACTIVITIES

OBLIGATIONS OF THE WHISTLEBLOWER

ALLEGATION IN BAD FAITH

SAFEGUARD

HOW TO RAISE CONCERNS

INVESTIGATION OF REPORTS

REVIEW OF POLICY

Introduction

Anchoria Investment and Securities Limited (“ANCHORIA” or “the Company”) is committed to encouraging a high ethical standard in all its business activities. It has established a code of ethics that sets out the standard of conduct expected in managing its businesses across the Group. All stakeholders are expected to comply with these standards in discharging their duties.
In furtherance of this, Anchoria’s Whistleblowing Policy and Procedures provides a channel for its employee and other relevant stakeholders to raise concerns about workplace malpractices confidentially; for the Company to investigate alleged malpractices and take steps to deal with such in a manner consistent with the Company’s policies and procedures and relevant regulations.
Whistleblowing for this Policy is the act of reporting perceived unethical conduct of an employee, management, directors, and other stakeholders by an employee or other persons to appropriate authorities.

Purpose

The purpose of this Policy is to provide a mechanism for reporting and investigating suspected cases of illegal and unethical conduct and any other misconduct in the business activities and to reinforce the Company’s non-victimization Policy for any stakeholder that reports a concern in good faith.
This Policy follows the requirements of various regulatory authorities with oversight on the Company’s activities on whistleblowing.

Scope

The Whistleblowing Policy applies to reporting and investigating fraudulent activities, illegal activities, and illegal conducts and safeguards available to whistleblowers. It does not apply to or change the Company’s policies and procedures for individual employee grievances and complaints relating to job performance and terms and conditions of employment. These would be handled through the Human Resources department in line with the provisions of the HR Policies and other applicable policies and procedures.
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This Policy covers the activities of Anchoria and is without prejudice to the requirements by the regulators of the Company to put in place a whistleblowing policy.

Responsibilities

The Internal Audit, Control & Compliance Officer shall have primary responsibility for implementing this Policy. In addition, the following obligations shall apply:

SN Responsible Officer Responsibilities
1
Whistleblower
Whistleblowers are expected to act in good faith. They should refrain from making false accusations when reporting their concern(s) and provide further evidence at their disposal to aid the investigation of the issues reported.
2
Suspect
The suspect must cooperate during the period of investigation, including the provision of relevant information, documents or other materials as may be required by the investigator
3
Internal Audit, Control & Compliance Officer
The Internal Audit, Control & Compliance Officer is expected to handle all matters with high professionalism, confidentiality and promptly. They shall be independent and unbiased in carrying out the investigation. • The Internal Audit, Control & Compliance Officer is responsible for acknowledging all concern(s) reported and reporting on the progress of the investigation to the whistleblower. • The Internal Audit, Control & Compliance Officer shall every quarter provide to the chairman of the Board Risk & Compliance Committee a summary of all cases reported and the result of the investigation. • The Internal Audit, Control & Compliance Officer/Investigator shall refrain from discussing or disclosing matters under investigation.
4
Head, Human Resources
The Head of Human Resources of the Company shall handle the report of investigation that relates to the entity's employees in line with the laid down disciplinary procedures as contained in the staff handbook.
5
Board Risk & Compliance Committee
The Chairman, Board Risk & Compliance Committee through the Company's Secretary, shall make available to all committee members quarterly report submitted by the Internal Audit, Control & Compliance Officer on whistleblowing concern(s) brought to the committee's attention with dispatch.
6
Internal Audit, Control & Compliance Officer
Review, update the whistleblowing policy and procedure and obtain requisite Board approval.

Definitions

For this Policy, the following definitions shall apply:
Whistle Blowing: this involves reporting events of misconduct or illegal activities relating to or affecting the Company.
Whistle Blower: any person who makes a protected disclosure about illegal or fraudulent activities or improper conduct.
Safeguards: arrangements made by the Company to protect a whistleblower.
Good faith: this is when the whistleblower sends their report without malice or consideration of personal benefit and believes the information to be accurate to the best of their knowledge.

Applicability

This Policy applies to all Anchoria stakeholders, including:
• Employees.
• Vendors and other service providers.
• Business partners and clients.
• Job applicants.
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• Official visitors.

Reportable Activities

The following activities shall be reported through Anchoria’s whistleblowing mechanism:
• Illegal activities.
• Fraudulent activities.
• Conflict of interest and abuse of office.
• Unethical practices.
• Insider dealing.
• Misuse of physical and information assets.
• Sexual harassment.
• Activities that constitute a danger to life and property
• All forms of bribery and corruption.
• Living above ones means.
• Under the influence of some substance
• Suppressed past criminal records.

Obligations of the Whistle Blower

The whistleblower shall take note of the following obligations:
• All whistleblowing reports should be made in good faith;
• The whistleblower should have reasonable ground to believe that the whistleblowing report is accurate; and
• The whistleblower should ensure that the report is not made to make personal gains.

Allegations in Bad Faith

Allegations confirmed to be made in bad faith shall result in disciplinary actions.

Safeguards

Harassment or victimization: Anchoria Investment and Securities Limited will not tolerate harassment or victimization for reporting concerns under this Policy and shall take all necessary steps to protect any stakeholder that reports a concern in good faith.
Confidentiality: Anchoria Investment and Securities Limited shall treat all reports and reporters with the highest regard for privacy.
Anonymity: whistleblowing reports can be treated anonymously. However, Anchoria encourages whistleblowers to put their names and contact information in the reports to properly handle appropriate follow-up questions and investigations.

How to Raise Concerns

i. As a first step, staff members are encouraged to raise concerns with their line managers or superiors. This depends, however, on the seriousness and sensitivity of the issues involved and the people thought to be involved in the reportable event.
ii. In general, concerns are better raised in writing and sent in a sealed envelope addressed to Internal Audit, Control & Compliance Officer or through a dedicated email address – [email protected]
iii. Concerns considered highly sensitive by the whistleblower as well as problems relating to Internal Audit, Control & Compliance Officer shall be sent to the Managing Director of Anchoria Investment and Securities Limited Ltd using [email protected]
iv. Concerns relating to the MD/CEO Anchoria Investment and Securities Limited shall be raised in writing and sent in a sealed envelope addressed to the Chairman, Risk Management and Compliance Committee
v. It is a serious disciplinary offence for any person to seek to prevent communication of concerns from getting to the Internal Audit, Control & Compliance Officer or MD/CEO Anchoria Investment and Securities Limited or the Board Risk Management & Compliance Committee or hinder any investigation arising from a whistleblowing report.
vi. All stakeholders are encouraged to note that ‘the earlier a concern is raised, the easier it is to act.

Investigation of Reports

i. All whistleblowing reports shall be thoroughly investigated.
ii. Whenever necessary, whistleblowers who indicated their names may be called upon to provide the evidence required to support concerns raised in the report.
iii. The outcome of the investigation shall be communicated to the whistleblower (where the whistleblower indicated their name).
iv. The Company shall take disciplinary measures against offenders for all confirmed events.
v. The Internal Audit, Control & Compliance Officer shall provide regular reports to the Managing Director on whistleblowing reports received in the Company and the investigation status.

Review of Policy

This Policy shall be reviewed every two years by the policy owner and may be amended, subject to approval if deemed necessary.