Reporting Policy and Procedures
Procurri Corporation Limited (the “Company” and, together with its subsidiaries, the “Group”) is committed to a high standard of compliance with accounting, financial reporting, internal controls and auditing requirements and any legislation relating thereto. In line with this commitment, this policy aims to provide an avenue for employees and external parties to raise concerns and offer them reassurance that they will be protected from reprisals or victimisation for whistle blowing in good faith.
1. Scope of Policy
This policy applies to all employees as well as to all external parties who have business relationships with the Group. These parties include customers, suppliers, contractors, applicants for employment, and the general public.
The main scope of whistleblowing policy covers:
- Fraudulent financial reporting
- Misappropriation of assets
- Improper or unauthorized expenditures (including bribery and other improper payment schemes)
- Unsafe work practices
- Material breaches of Group policy
- Violations of laws and regulations (including those that expose the company or its agents to regulatory or criminal actions. e.g. securities frauds)
- Any other matters involving fraud, corruption and employee misconduct
- It is the Audit Committee's responsibility to ensure that the Company has appropriate procedures for the receipt, retention and treatment of disclosures or complaints about the Company's accounting, internal accounting controls or auditing matters.
- All concerns raised will be treated fairly and properly.
- All concerns will be handled confidentially, except as necessary or appropriate to conduct investigation and to take remedial action, in accordance with the applicable laws and regulations.
- The Company encourages the complainant to identify himself/herself when raising a concern or providing information and will take all reasonable steps to protect the confidentiality and identity of a complainant subject to applicable laws and regulations.
- The Company will ensure no one will be at risk of suffering some form of retribution as a result of raising a concern even if they turn out to be mistaken. The Company does not however extend this assurance to someone who maliciously raises a matter he/she knows to be untrue. This policy is not a route for taking up personal grievances.
3. Procedures for Whistle Blowing
3.1 How to Raise a Concern or Provide Information
Employees are free to bring complaints to the attention of their supervisors, the Human Resources Department or the Legal Department. The recipient of such complaints will forward them promptly to the Audit Committee Chairman. Employees may also drop the report into the locked letterbox marked "Audit Committee, Procurri Corporation Limited" located in HR Department. Any report so received will be forwarded unopened to the Audit Committee Chairman.
If none of the channels above are suitable, the complainant can address his/her concerns directly to the Audit Committee Chairman. Reports are preferably made in writing and may be sent to 29 Tai Seng Avenue #01-01, Natural Cool Lifestyle Hub, Singapore 534119, in a sealed envelope, marked "Private and Strictly Confidential - Attention: Audit Committee Chairman, Procurri Corporation Limited". Alternatively, the complainant can raise his/her concerns by email to the Audit Committee Chairman, Mr. Peter Ng Loh Ken at firstname.lastname@example.org.
As it is essential for the Group to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should set out the background and history of events as well as the reason(s) for concern, evidence substantiating the complaint, and where possible, the contact details of the complainant, in case further information is required.
The Audit Committee Chairman will inform the Audit Committee of all complaints received, with an initial assessment as to the appropriate treatment of each complaint. All matters reported will be reviewed within a reasonable timeframe, and after due consideration and inquiry, a decision will be taken on whether to proceed with a detailed investigation.
If the Audit Committee deems it appropriate to proceed with a detailed investigation, the complaints will be directed to an investigation team headed by the Group Chief Financial Officer or such other person as the Audit Committee may direct. Investigations into the complaints will be conducted discreetly, and any personal information which was given would only be use d and /or disclose d in furtherance of investigation of the matter reported. The Audit Comm ittee will disclose the information it collects to the designated internal investigator to act on the complaint received , or as and when required by law or regulatory authorities
Furthermore, depending on the nature of the concern raised or information provided, if the Audit Committee deems it appropriate, it may engage at the Company's expense, independent advisers, external counsel or external auditor.
Following investigation and evaluation of a complaint, the investigation team will report the findings together with recommended action(s) to the Audit Committee. The action determined by the Audit Committee to be appropriate shall then be brought to the Board or to appropriate members of senior management for authorization and implementation respectively.
3.3 Retention of Records
Records pertaining to the complaint and the investigation, if any, shall be the property of the Company and shall be retained by the Company in compliance with applicable laws and the document retention policies of the Company.
The records will be subject to appropriate safeguards to ensure their confidentiality and, where applicable, to protect the identity of the complainant.