Whistle Blowing Policy

WHISTLE BLOWING POLICY AND PROCEDURES

Whistle Blowing

1. Whistleblowing is the term used when a worker or stakeholder passes on information concerning wrongdoing through established channels. The wrongdoing could typically be something they have witnessed at work. Personal grievances and complaints are not covered by the whistleblowing policy.

2. The worker / stakeholder who makes a disclosure (“whistle-blower”) shall be:

• reporting in good faith and acting in the public interest;
• the disclosure tends to show past, present or likely future wrongdoing falling into the following categories: fraud, sexual harassment, failure to comply with regulatory requirements, miscarriages of justice, misappropriation of assets, misuse of confidential information, endangering someone’s health and safety, damage to the environment and covering up wrongdoing in the above categories;

3. If the allegations are proven to be malicious, parties responsible may be treated as a misconduct and subject to appropriate action, up to and including legal action, where applicable.

Employer’s Responsibilities

The company shall create an open, transparent and safe working environment where workers feel able to speak up. By having clear policies and procedures for dealing with whistleblowing, the company demonstrates that it welcomes information being brought to the attention of management.

Procedures

1. Employees who may consider that there are grounds for enquiry into wrongdoing, the concerns should be raised to the immediate superior. If it is not appropriate, then the concern should be reported to Human Resource Manager i.e. Puan Yanti at yanti@hovid.com.
2. In the case where reporting to management is a concern, the report should be made to the Managing Director i.e. Mr David Ho at dho@hovid.com or the Chairman of Audit Committee i.e. Mr. Chiam Tau Meng at chiamtm@gmail.com.
3. Reports received will be treated as confidential.
4. The person making anonymous report will be advised that maintaining anonymity may hinder an investigation. Irrespective of this, anonymity will be maintained as long as it’s permitted by law or the person making the report indicates that he no longer wishes to remain anonymous.
5. All reports will be investigated promptly by the person receiving the report. A summary of matters reported will be tabled every quarter to the Audit Committee.
6. Upon completion of investigation, appropriate course of action will be recommended to the Managing Director or the Audit Committee Chairman for their deliberation.
7. Where possible, steps will also be implemented to prevent similar situation arising.
8. The company commits to treat all disclosures consistently and fairly.
9. The company commits to take all reasonable steps to maintain the confidentiality of the whistle-blower where it is requested.

Protection from Retaliation

The company emphasizes that victimization of a whistleblower is not accepted. Any instances of victimization will be taken seriously and managed appropriately. Any party that retaliates against the whistleblower will be subject to appropriate action, up to and including legal action, where applicable.