1.1 Broadway Industrial Group Limited (the “Company”) is committed to a high standard of corporate governance to safeguard shareholders’ interests and the assets and reputation of the Company and its subsidiaries (together the “Group”) as a whole.
1.2 This Whistleblowing Policy (this “Policy”) aims to: (i) provide an open and confidential process for the Group’s employees, suppliers, customers and other stakeholders to raise genuine concerns on any serious wrongdoing; (ii) encourage individuals to be confident in raising genuine concerns without fear of reprisal, discrimination or adverse consequences; and (iii) ensure that robust arrangements are in place to facilitate independent investigation of any actual, suspected or anticipated wrongdoing within or by the Group.
2. REPORTABLE INCIDENTS
2.1 Examples of reportable incidents may include, but are not limited to the following, whether actual, suspected or anticipated: (i) financial or professional misconduct; (ii) corruption, bribery, misappropriation, blackmail, forgery, fraud, or any conduct which is an offence by law; (iii) irregularity or non-compliance with laws/regulations and/or internal controls; (iv) breach of legal obligation; (v) serious conflict of interest without disclosure; (vi) use of the Group’s funds in an unauthorised manner; (vii) intentional provision of incorrect information to public bodies; (viii) dangerous or unsafe work environment; (ix) sexual or physical abuse; (x) concealing information about any malpractice or misconduct; and (xi) any other improprieties or matters that may adversely affect shareholders’ interests and the Group’s assets and reputation.
3.1 The Group will not tolerate the harassment or victimisation of any individual reporting a genuine concern or providing information about an actual, suspected, or anticipated wrongdoing. Such individuals will be protected against any reprisal such as employment termination, retribution, or harassment. All reports will be treated fairly and properly.
3.2 All reports must be made in good faith. This Policy is not intended to be used for taking up personal grievances, or for reporting issues that are (i) not factual, (ii) trivial, frivolous and vexatious in nature, or (iii) where the reported incident or subject has no relevance to the Group. Any false, misleading and frivolous claims will be disregarded.
3.3 Whistleblowing reports should not include operational issues, such as receiving feedback or complaints from customers which should be dealt with at the Management level, or human resource or other issues for which there are proper channels in place. If any employee believes reasonably and in good faith that malpractice exists in the workplace, he or she should report this as soon as practicable to his or her immediate manager. Alternatively, he or she may report their concerns to the Human Resource Department.
4. REPORTING PROCESS
4.1 Genuine concerns on any serious wrongdoing within or by the Group may be raised in writing to:
Private & Confidential
For the Attention of the Audit Committee Chairman
BROADWAY INDUSTRIAL GROUP LIMITED
3 Fusionopolis Way
#13-26 Symbiosis Tower
Email Address: firstname.lastname@example.org
4.2 All concerns raised will be independently reviewed by the Audit Committee and all information provided will be kept strictly confidential, except as necessary and appropriate to conduct any relevant investigation(s). Where a police report is required to be made, the identity of the reporting individual and the information provided by that individual may have to be revealed in the investigation process.
4.3 Reports should be made as soon as practicable, and include, in as much detail as possible, the identity and particulars of the parties involved, background, history of events, relationship or interest and any other relevant information or documentation that would assist in the investigation.
4.4 As soon as reasonably practicable and to the extent legally permissible, the Company will, as it considers appropriate, write to the individual who has reported the incident in good faith: (i) acknowledging that the concern has been received; (ii) requesting for further information from that individual; (iii) informing the individual whether an investigation will take place, and if not, the reason for not proceeding further; and/or (iv) advising the status or outcome of the investigation, if any.
4.5 Where appropriate and depending on the gravity of the incident, the Audit Committee will independently review the concern and may: (i) lead the investigation internally; (ii) consult with the Board of Directors, Management, Company Secretaries, Internal Auditors, External Auditors and legal advisers; (iii) direct to the best department or persons to address the concern; (iv) refer to the police; (v) resolve by agreed action without the need for investigation; and/or (vi) convene an independent enquiry.
4.6 The Group reserves the right to refer any concerns to the relevant external authorities and/or take any appropriate internal disciplinary actions or measures.
This Policy is disseminated to employees of the Group and published on the corporate website.
6.1 The Audit Committee will report the significant matters raised through the whistleblowing channel, if any, to the Board of Directors on a quarterly basis.
6.2 The Audit Committee is responsible for implementing and reviewing this Policy on a regular basis.
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