Whistleblowing is the voluntary reporting of suspected malpractice, wrongdoing, irregularities, impropriety, statutory non-compliance or dangers in relation to the Company’s activities. As the Company adopts a zero-tolerance approach, this policy has been established to:
- deter and eliminate all possible fraud within the Company
- implement robust arrangements that give confidence to all individuals, internal and external, to raise concerns on unethical conduct, without fear of reprisals when whistleblowing in good faith
- handle all concerns raised professionally, fairly, and expeditiously
- encourage timely reporting of alleged misconduct
- ensure consistent and timely response to reported improprieties
- create awareness regarding Whistle-blower’s rights
- promote a culture of openness, accountability, and integrity
Non-exhaustive aspects requiring whistleblowing regardless of whether the malpractice has occurred, is in progress, or is likely to occur are:
- financial fraud or mismanagement in accounting
- non-financial malpractice or impropriety
- corruption, misappropriation, or blackmail
- harassment, abuse and misrepresentation of power and authority
- any criminal offence
- failure to comply with any legal or professional obligation or regulatory requirements
- breach of internal policies and procedures
- endangerment of the health and safety of an individual
- damage to the public and/or the environment
- unethical or improper conduct
- conduct likely to have adverse impact on the Company’s operations and/or reputation
- conflicts of interest not declared
- negligence in the discharge of duties
- unauthorised disclosure of confidential information
- the deliberate suppression and/or concealment of any of the above matters
The Company takes reasonable measures to protect the identity of the Whistle-blower and keep disclosed information confidential, limited only by the extent necessary to conduct an adequate and effective investigation and to invoke any remedial action, in accordance with applicable laws and regulations. All discussions and records pertaining to the investigation will be retained according to the Company’s retention policies and classified confidential.
Whistle-blowers are encouraged to identify themselves and provide contact details as anonymity makes it more difficult for the Company to protect his/her identity or provide updates regarding the investigation.
On occasion, Whistle-blowers could be approached but are not obligated to come forward as witness, under the protection and support of the Company.
No Whistle-blower shall suffer reprisal as a result of reporting a genuine concern. Whistle-blowers are not expected to prove the truth of his/her concern beyond reasonable doubt, nor does it matter that the Whistle-blower is eventually mistaken if there is information that suggests malpractice, rather than an opinion or a feeling. This assurance does not extend to any Whistle-blower found to have made the allegation frivolously, acted maliciously for personal gain, outside of good faith and the best interests of the Company, and/or has intentionally provided information known or reasonably believed to be false. Such behaviour will be deemed criminal and handled by the relevant authorities.
Any Whistle-blower believed to be subject to discrimination, retaliation, harassment, or adverse consequences for having raised a concern, shall at the soonest practicable opportunity report such behaviour to Compliance and be protected from such.
Whistleblowing may be received from internal and external sources. Internally raised concerns refer to employees who report incidents observed internally. Externally raised concerns refer to anyone who is not an employee of the Company, who report misconduct on employees of the Company.
Concerns can be raised by telephone, in person or in writing, prescribed in the table below. For investigation to be effective and thorough, the sufficiency and quality of information provided should be detailed and specific, minimally:
- Nature and context of the concern
- Date, time and place of the occurrence
- Identify parties involved
- Relationship to the situation/parties involved
- Why you believe it to be true, supported by evidence substantiating the allegations
- Contact details (optional)
|Anonymous link||Whistleblowing / Fraud reporting|
+65 6323 0451
+852 2162 7832
|Attn: Compliance Manager
8M Real Estate Private Limited
88A Amoy Street, Singapore 069907 Attn: Compliance Officer
27th Floor, 8 Queen’s Road Central, Central, Hong Kong
This reporting mechanism excludes employee grievances which are handled by HR.
Employees who feel uncomfortable raising concerns internally especially if it is believed that the Company itself is responsible for the malpractice, are dissatisfied about the speed or conduct of the investigation, and/or the way in which the matter has been resolved and yet still reasonably believe the allegations to be substantially true, are to refer such matters to the appropriate external regulatory authorities, upon prior written approval of Compliance.
Equally, the Company recognises that there may be matters which cannot be resolved internally and reserves the right to refer any such matters to the appropriate external regulatory authorities.