Policies and Standard Operating Procedures on Whistleblowing.
Octopus (APAC) Holdings Limited (the “Company”) and its subsidiaries (collectively, the “Group”) have drawn up and implemented the following policies and Standard Operating Procedures (“SOP”) to provide a framework for reporting and addressing concerns related to unethical, illegal, or otherwise inappropriate activities within the organization. This policy aims to ensure that individuals feel safe and supported when raising such concerns and that these concerns are handled promptly and effectively.
This SOP applies to all directors, key management personnel, employees, contractors, consultants, suppliers, and any other stakeholders who have a relationship with the organization.
In this policy, the following words shall have the following meanings:
The organization is committed to maintaining a culture of integrity and accountability. Whistleblowers are encouraged to report any concerns they may have, without fear of retaliation or reprisal.
5.1 The ARC Chair will conduct an initial review of the report to determine if further investigation is warranted. If the report is deemed to have merit, a formal investigation will be initiated.
5.2 If a formal investigation is required, a designated investigation team will be appointed and headed by the ARC Chair. The investigation team will gather evidence, interview relevant parties, and document findings.
5.3 The findings will be documented in an investigation report which will detail the appropriate actions to be taken based on the findings. The whistleblower will be informed of the outcome, if possible and appropriate.
6.1 The organization prohibits any form of retaliation against whistleblowers.
6.2 Any individual found to have retaliated against a whistleblower will be subject to disciplinary action, up to and including termination of employment.
7.1 All reports and investigations will be handled with the utmost confidentiality.
7.2 Information will only be disclosed on a need-to-know basis.
8.1 All reports and related documentation will be securely stored and maintained by the ARC Chair.
8.2 Records will be retained for a minimum of 6 years.
9.1 This SOP will be reviewed annually and updated as necessary to ensure it remains effective and compliant with legal requirements.
9.2 The ARC Chair is responsible for the review and update of this SOP.
For and on behalf of the Board
Loo Hee Guan
Executive Director