Operating Policies and Procedures Whistle Blowing Policy - RESTRICTED Version Effective Date
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Operating Policies and Procedures
Whistle Blowing Policy
Version 1.0
Effective Date 30th Jan 2015
RESTRICTEDTable of Contents
1. Policy Statement ........................................................................................... 1
2. Introduction ................................................................................................... 1
3. Principles ....................................................................................................... 1
4. Procedures .................................................................................................... 2
5. Further Information ....................................................................................... 5
RESTRICTEDInfraCo Asia
Operating Policies and Procedures – Whistle Blowing Policy
1. Policy Statement
It is the responsibility of every employee to ensure that InfraCo Asia and its
subsidiaries are committed to operating lawfully, ethically and with integrity. However,
from time to time there may be situations where the right course of action is unclear,
or there may be situations where something improper, unethical or inappropriate is
suspected or known. This Policy has thus been established to ensure that all cases
of suspected wrongdoing are reported and managed in a timely and appropriate
manner.
2. Introduction
All employees and external parties are encouraged to raise genuine concerns about
possible improprieties in the conduct of InfraCo Asia’s business activities and that of
its developers/sub-contractors at the earliest opportunity and in an appropriate way.
The policy is designed to:
ensure all employees and external parties feel supported in speaking up with
confidence and reporting matters they suspect may involve anything, improper,
unethical or inappropriate;
encourage all improper, unethical or inappropriate behaviour to be identified and
challenged at all levels of the organisation;
provide clear procedures for the reporting of such matters;
manage all disclosures in a timely, consistent and professional manner; and
provide assurance that all disclosures will be taken seriously, treated as
confidential and managed without fear of retaliation.
3. Principles
All concerns raised will be treated fairly and properly.
Harassment or victimization of anyone raising a genuine concern will not be
tolerated.
Any individual making a disclosure will retain his/her anonymity unless he/she
agrees otherwise.
Any individual raising a concern should be aware of who is handling the matter.
No one should be at risk of suffering some form of retribution as a result of raising
a concern, even if he/she is mistaken. This assurance is, however, not extended
to someone who maliciously raises a matter that is known to be untrue.
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Operating Policies and Procedures – Whistle Blowing Policy
4. Procedures
4.1 Reportable events or incidents
Whistle blowing refers to a disclosure of information made by an employee or an
external party where he/she reasonably believe that a reportable event or incident is
happening now, took place in the past or is likely to happen in the future.
The following is a non – exhaustive list of examples of integrity violation, wrongdoing
or malpractice that would constitute a reportable event or incident:
Criminal offences;
Fraud;
Corruption;
Failure to comply with a legal or regulatory obligations;
Miscarriage of justice;
Endangering the health and safety of any individual;
Endangering any elements of the environment;
Concealment of information tending to show any of the above.
4.2 Reporting in good faith
The management of InfraCo Asia undertakes that no one who reports any concern
under this policy in good faith will be subjected to any detriment by the InfraCo Asia
or any person within the control of InfraCo Asia for coming forward, regardless of
whether or not the concern is ultimately substantiated. In the event that a reporting
party believes that he/she is being victimised or subjected to a detriment by InfraCo
Asia or any person within the control of InfraCo Asia as a result of reporting a concern
or assisting the company in any investigation under this policy, the Chairman of Audit
& Risk Management Committee must be informed immediately and appropriate
action will be taken to protect him/her from any reprisal by InfraCo Asia or any person
within the control of InfraCo Asia.
If during the course of the investigation it is discovered that the matter has not been
reported in good faith, the reporter will be subject to investigation and potential
disciplinary action maybe be taken by the management or the Chairman of Audit &
Risk Management Committee. In the event if the reporter is external party, the
Chairman of Audit & Risk Management Committee and the management of InfraCo
Asia reserve the right to pursuit against the external party for false statement that
harms the reputation of InfraCo Asia.
4.3 Employee’s responsibilities
This policy can be used by any officer, employee, group of employees and external
party. In addition, management/developer services providers should also adopt
whistle blowing policies consistent with this mandate established by the management
of InfraCo Asia and report any suspected wrongdoings to the Chairman of Audit &
Risk Management Committee of InfraCo Asia.
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Operating Policies and Procedures – Whistle Blowing Policy
4.4 Escalation Process
If any employee believes reasonably and in good faith that malpractice or
misconduct that constitutes a reportable event or incident has occurred or is
occurring in the work place, then he/she should notify the matter to the line
manager directly and the line manager must inform the Audit & Risk Management
Committee within 3 business days. If the disclosure involves the line manager, the
employee should notify the Chair of Audit & Risk Management Committee at
bob.edgell@infracoasia.com
If any external party believes reasonably and in good faith that malpractice or
misconduct that constitutes a reportable event or incident has been or is being
perpetrated by an employee of by InfraCo Asia or its developers/subcontractors,
the whistle-blower should notify the Chair of the Audit & Risk Management
Committee at bob.edgell@infracoasia.com.
4.5 Information to be provided by the whistle-blower
Concerns may be raised by email, orally or in writing.
Where possible, the following information should be included:
an outline of the known or suspected wrongdoing;
details, to the best of whistle-blower’s knowledge, about when, where and how it
occurred;
a list of the names of those suspected of being involved (both within InfraCo Asia
and externally);
a list of the names of anyone who may have relevant information;
details of how the whistle-blower came to know about the suspected activities;
what, if any, do you estimate to be the value of the loss to InfraCo Asia or other
parties;
what, if any, breaches of internal controls, policy, procedure or other requirements
you believe took place;
any relevant supporting evidence;
any specific recommendations that the whistle-blower have for actions;
the names of person whom the whistle-blower has discussed or reported this
incident to;
whistle-blower’s name and contact details. Please note – these will be kept
confidential as far as is reasonably practicable; and
the date and time of making the report.
4.6 Anonymity
It is understood that disclosures made under this policy may involve highly
confidential and sensitive matters and that the whistle-blower may prefer to make an
anonymous disclosure. The Chair of the InfraCo Asia Audit and Risk Management
Committee will endeavour to investigate the concerns fully, although a full
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Operating Policies and Procedures – Whistle Blowing Policy
investigation may be impeded if further relevant information is not available from the
whistle-blower.
4.7 Post-reporting process
The Chair of the InfraCo Asia Audit and Risk Management Committee will
acknowledge receipt of whistle-blower’s concern within 3 working days and contact
the whistle-blower to discuss the next steps.
4.8 Investigation
InfraCo Asia Audit and Risk Management Committee will decide how to respond in a
responsible and appropriate manner under this policy. Any investigation will be
undertaken in accordance with the investigation procedures set out in the Private
Infrastructure Development Group (PIDG) Operating Policies and Procedures
(Chapter 2).
The purpose of this investigation is:
to establish if a wrongdoing has occurred, and if so to what extent; and
to minimise the risk of further wrongdoing, to prevent any further loss of assets,
damage to reputation and to protect all sources of evidence.
InfraCo Asia Audit and Risk Management Committee will endeavour to handle
investigations as consistently, promptly and fairly as possible.
Any person found to be involved in any wrongdoing will be subject to internal
disciplinary action. Where it is believed that criminal activity has taken place, the
matter may be reported to the police and appropriate legal action may be taken.
The management of InfraCo Asia should ensure that whistle-blowing complaints are
adequately addressed. In this regard, periodic reports on complaints should be
submitted to InfraCo Asia Board via the Audit & Risk Management Committee.
Subsequently, the InfraCo Asia Board shall issue a consolidated report to the PIDG
for review.
A summary report on the investigations conducted should include information such
as the source of complaints, volume and type of complaints, how complaints were
addressed (i.e. whether disciplinary action was taken against staff who breached
internal guidelines or failed to uphold the requisite standard of professionalism in
discharging their duties)
4.9 Data protection and privacy
All information provided by and relating to the whistle-blower shall be treated
confidentially as far as reasonably practicable. There may be circumstances where,
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Operating Policies and Procedures – Whistle Blowing Policy
because of the nature of the investigation or disclosure, it will be necessary to
disclose the whistle-blower’s identity. In such circumstances, the whistle-blower will
be informed before such disclosure is made.
5. Further Information
For further questions about the content or application of this policy, please contact:
for employees of the company, your line manager
for all other parties, the Chair of the Audit and Risk Management Committee
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