The Group has adopted a Whistleblowing Policy and the following sets out the policy and procedures by which you can report your concerns. The Whistleblower can be assured that the information will be examined carefully and if it has merit will be acted on. The whistleblower (internal and external) can be assured that the Group intends to protect its business and reputation.
SOG takes all malpractice very seriously, whether it is committed by an employee, supplier customer, competitor or contractor.
This Policy Statement applies to all employees, agents and consultants. It is intended to complement statutory protection and, for the avoidance of doubt, statutory rights will not be affected in any way by this policy.
The following examples demonstrate what we mean by serious malpractice:
If you become aware of any such activities or other possible malpractices, you are encouraged to follow the procedures set out below. It will not always be clear that a particular action falls within one of these categories, and you will need to use your own judgment. However, if you believe the matter to be serious, SOG would prefer you to report your concerns rather than keep them to yourself.
How do I make a report?
You can make a report orally or in writing. Normally, for employees, you should inform your immediate manager, or their line manager.
Historically, a direct whistleblowing channel through email has been implemented to enable our stakeholders to get direct access to our Audit Committee Chairman. With effect from February 2018, the Company has assessed the need to have more than one whistleblowing channels and our stakeholders can now use any of the following whistleblowing channels:
Is there a place where I can go for independent advice?
Go first to the Audit Committee Chairman who is an independent non-executive director and who can hire lawyers, if required.
Do I need proof of wrongdoing to make my report?
SOG does not expect you to have absolute proof of any malpractice that you report. However, you will need to be able to explain the reasons for your concern. Whilst the Group wishes to encourage whistleblowing, it will not tolerate spurious or vindictive allegations.
How will my report be investigated?
Once you have made a report, the Audit Committee Chairman or an unrelated (to the incident or person being reported) SOG senior management will acknowledge receipt of it within 10 working days.
An independent person will then make preliminary enquiries as confidentially as possible. If the person raising the concern is required to attend face-to-face meeting, a fellow employee may accompany him or her where appropriate.
If it is determined that a fuller investigation is necessary, this will proceed either with further internal investigations, or by referral to an appropriate external body, dependent upon the nature and the seriousness of the report.
Will SOG protect my identity if I make a report?
If you make a report, SOG will do everything possible to keep your identity as confidential as possible during the investigation and you may assume that only the SOG person investigating the malpractice concern will know your identity. However, there may be circumstances (for example, if your report becomes the subject of a criminal investigation) where you may be needed as a witness and, once the investigation is complete, the findings may need to be communicated to the individual(s) concerned (see below). Should this be the case we will discuss the matter with you at the earliest opportunity.
Can I protect my identity by reporting on a confidential basis?
The Group would prefer you to give your name and contact details when you make a report. However, you are also allowed to communicate your concern on a confidential basis.
What will happen on completion of the investigations?
Subject to any legal constraints, SOG will communicate the findings of the investigation to:
As with any case where an employee is found to be involved in wrongdoing, they will be dealt with effectively in accordance with employment laws and contracts of employment.
Am I at risk of suffering victimisation if I raise a report?
You can be assured that, if you raise an important concern, this will be taken seriously and you will be treated fairly and with discretion. We will take all reasonable steps to ensure that no person under our control engages in victimisation of any form. If you make a report in good faith, even if it is not confirmed by an investigation, your concern will be valued and appreciated and you will not be liable to disciplinary action. However, if you make a false report, maliciously or for personal gain, then you may face disciplinary action.
What can I do if I am unhappy with the way SOG has dealt with my report?
If you are unhappy with the outcome of an investigation, you should submit another report explaining why this is the case to the whole of the Board of Directors. Your concern will be investigated again if there is a good reason to do so.
If you are still unsatisfied with the result, you may make a report to the Singapore Stock Exchange or any other Singapore authorities you wish.