Email This Print ThisWhistle-blowing Policy

To reaffirm its commitment to good corporate governance, TeleChoice International Limited (the “Company”) has implemented a whistle-blowing policy in accordance with the guidance set out in the Singapore Code of Corporate Governance (2018).

The whistle-blowing policy provides an avenue for the directors, employees and key stakeholders (such as contractors) of the Company and/or its subsidiaries, and any other person to raise, in confidence, concerns about possible improprieties in matters of financial reporting and questionable accounting practices, or other matters such as criminal offences, unlawful acts, fraud, corruption, bribery and blackmail, failure to comply with legal or regulatory obligations, unsafe work practices or substantial wasting of resources of the Company and/or its subsidiaries, inappropriate behavior such as abuse of power or authority, breach of any code of conduct for employees, conflicts of interests (including secret personal gains), miscarriage of justice and concealment of any of the foregoing. The policy also outlines the procedural framework to promote responsible and secure whistle-blowing, without fear of reprisal, discrimination or adverse consequences.

Details of the whistle-blowing policy have been made available to the directors and employees of the Company and its subsidiaries.

Purpose

The objectives of the whistle-blowing policy are:

  1. Support the Company’s and its subsidiaries’ values and help detect and address unacceptable conduct;
  2. Afford an avenue for directors, employees and key stakeholders (such as contractors) of the Company and/or its subsidiaries, and any other person, to raise concerns without fear of retribution and offer reassurance that any person making such reports will be treated fairly and protected from reprisals for whistle-blowing in good faith within the limits of the law; and
  3. Provide a transparent and confidential process for dealing with concerns.

Reporting Channels

Incidents of actual or suspected possible improprieties can be reported anonymously or otherwise, to the Company Secretary at email: feedback@telechoice.com.sg or tel: 6826 3677. Apart from the reporting channels above, employees may also choose to raise any concerns to their immediate superior or escalate their concerns to their next-level superior.

Review and Investigation

The Audit Committee of the Company (“AC”) oversees the administration of the whistle-blowing policy. To ensure independent investigation into such matters and for appropriate follow-up action, all whistle-blowing reports shall be channeled to the AC for its review. In the event that the whistle-blowing report is about a member of the AC, that AC member shall not be involved in the review of, and any decisions with respect to, that whistle-blowing report.

All reports, including unsigned reports, reports weak in details and verbal reports, will be considered. However, anonymous reports may not be given the same level of attention. Upon receipt of any reports, the AC may:

  1. Conduct its own investigation or review, and instruct the relevant members of management as determined by AC to take such remedial action as deemed appropriate by the AC;
  2. Instruct the relevant members of management as determined by AC to conduct investigation or review and to take such remedial action as deemed appropriate by the AC;
  3. Engage third parties as determined by the AC to conduct investigations or review and instruct the relevant members of management as determined by AC to take such remedial action as deemed appropriate by the AC;
  4. Report the matter to the authorities if there is reason to believe that a crime has been committed; and/or
  5. Take any other action as the AC may determine in the best interests of the Company and/or its subsidiaries.

Periodic reports will be submitted by the AC to the Board of Directors of the Company stating the number and details of the complaints or reports received, the results of the investigations into such compliants or reports, the follow-up actions and the unresolved complaints or reports.

Safeguard

Discrimination, retaliation or harassment of any kind against a whistle-blower who submits a complaint or report in good faith is prohibited, and appropriate steps will be taken to ensure that the complainant suffers no detriment or retaliation as a result of raising concerns in accordance with this policy. If a complainant believes that he or she is being subjected to discrimination, retaliation or harassment for having made a compliant or report under this policy, he or she should immediately report those facts to the President of the Company or any member of the AC to the investigations and the taking of appropriate action.

Should the investigations warrant, the whistle-blower making the report or complaint may be required to come forward as a witness at the appropriate time. If the whistle-blower makes an allegation in good faith but it is not confirmed by the investigations, no action will be taken against him or her. If, however, the whistle-blower makes an allegation frivolously, maliciously, in bad faith or mischief, for personal gain, or knowing it to be untrue or unfounded, he or she will not be protected. Administrative and/or disciplinary actions not limited to the termination of employment or other contract, the taking of legal action and/or reporting of the matter to the police, may be taken.

A whistle blower who raises a concern or makes a report under this policy does not have to be directly or personally affected by the violation or potential violation or have a personal interest in the outcome of the report. Such person would not be expected to prove the case, and his or her duty is simply to raise the concern so that the appropriate parties can address it in accordance with this policy. In rare situations where the whistle blower raising the concern or reporting the violation has a personal interest in the outcome of any investigation, then he or she may be called upon to prove his or her case.

This policy is not intended to address employees’ complaints or personal grievances. For grievances concerning work related matters, please refer such matters to the relevant Human Resource representative.

Confidentiality

Every effort will be made to protect the whistle-blower’s identity so long as it is compatible with a proper investigation. However, it is important to be aware that it may be necessary to reveal the identity of the whistle-blower under certain circumstances, including where:

  1. The identity of the complainant is material to any investigation;
  2. The information is given on a confidential basis to legal, auditing or third party professionals for the purpose of obtaining professional advice;
  3. Required by law, or by the order or directive of a court of law, regulatory body or such other body that has jurisdiction and authority of law to require such identity to be revealed;
  4. The AC is of the opinion that it would be in the best interests of the Company or its subsidiary to do so;
  5. It is determined that the complaint or report was frivolous, made in bad faith, in abuse of this policy or lodged with malicious or mischievous intent; or
  6. The identity of the complainant is already public knowledge.

Policy Review

The AC shall review this policy on a regular basis and may, from time to time, recommend amendments to maintain compliance with applicable laws and regulations or accommodate organisational changes, for approval by the Board of Directors of the Company.