1. POLICY PURPOSE
1.1. Cuscaden Peak Investments Private Limited and its subsidiaries (“CPI” or the “Group”) do not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff in the course of their work. This Policy is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences.
1.2. The Policy aims to create a work environment where Employees, vendors, service providers, customers and other stakeholders are able to raise concerns on misconduct, irregularities or malpractices, without fear of harassment and/or victimization and with an assurance that their concerns will be taken seriously and investigated, and the outcome duly communicated.
1.3. It is intended to encourage staff and other relevant stakeholders to report unethical or illegal conduct. Policy objectives include:
1.3.1. Encourage timely reporting of alleged malpractices/misconduct;
1.3.2. Provide a confidential channel for escalation of concerns without fear of reprisal;
1.3.3. Ensure consistent and timely response to reported improprieties and awareness by whistleblowers of their options/rights;
1.3.4. Ensure appropriate oversight by the Board of Directors;
1.3.5. Serve as a means of preventing and deterring misconduct that may be contemplated;
1.3.6. Protect the rights of CPI; and
1.3.7. Promote a culture of openness, accountability and integrity.
2.1. This Policy applies to:
2.1.1. CPI and its subsidiaries where CPI or its subsidiaries have management control;
2.1.2. All Employees (including those of its subsidiaries where CPI or its subsidiaries have management control) including but not limited to the following: officers, directors, freelance/part-time workers, trainees, seconded staff, interns, or any other person associated with us (collectively referred to as “Employees” in this Policy); and
2.1.3. Third Party Representatives (as defined in Paragraph 3.3 below); and
2.1.4. External Parties (as defined in Paragraph 3.1 below).
2.2. The Policy allows for reporting by Employees or External Parties of such matters to the Internal Audit Division of CPI, without fear of reprisal, discrimination or adverse consequences, and also permits CPI to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.
2.3. Reportable incidents for whistleblowing include:
2.3.1. All forms of financial or non-financial malpractices or impropriety such as fraud, corruption, bribery or theft.
2.3.2. Harassment and abuse and misrepresentation of power and authority;
2.3.3. Failure to comply with laws and regulations;
2.3.4. Actions detrimental to health and safety or the environment;
2.3.5. Discrimination on the basis of gender, race, disabilities;
2.3.6. Serious conflict of interest without disclosure;
2.3.7. Breach of CPI’s policies or Code of Ethics; and
2.3.8. Concealing information about any of the above malpractice or misconduct.
2.4 Whilst the whistleblowing procedures allow anyone to report possible improprieties, it excludes employee grievances or disagreements which should be handled by the CPI Human Resources Division.
3.1. “External Parties” refer broadly to, but not limited to, members of the public or those who are impacted by various organisational or business activities of CPI.
3.2. “Receiving Officer” refers to the Head of the Internal Audit Division who is responsible for the investigation, handling and escalation of reportable concerns.
3.3. “Third Party Representative” refers to any outside party acting on behalf of CPI and its subsidiaries. Third Party Representatives consist of but may not be limited to the following: agents, consultants, distributors, business partners, contractors, agents, agency staff, joint-venture partners and certain vendors but shall not include brokers. For example, vendors that do not represent CPI in dealing with Customers and Government Officials and which only supply goods to CPI are not considered being Third Party Representatives. Similarly, brokers hired by Customers to assist with selecting vendors are not considered to be “Third Party Representatives”.
3.4. “Whistleblowing” refers to a voluntary disclosure of individual or organisational malpractice by a person who has privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing or malpractice within or by CPI that is within its ability to control. There are two categories of whistleblowers, namely:
3.4.1. “Internal Whistleblowers” refers to Employees who are expected to report incidents of misconduct involving peer, supervisor/superior or top management staff to relevant reporting point.
3.4.2. “External Whistleblowers” refers to customers, suppliers, service providers and other members of the public who report wrongdoings of Employees to the Head of Internal Audit/ Chief Executive Officer.
4.1. CPI encourages Employees and External Parties to put their names to their allegations whenever possible. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the following:
4.1.1. Seriousness of issues raised;
4.1.2. Significance and credibility of concerns;
4.1.3. Likelihood of confirming the allegation from attributable sources and information provided.
4.2. All valid concerns or irregularities raised will be acknowledged and treated with confidence throughout the process.
4.3. Concerns may be raised verbally or in writing. As it is essential for CPI to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The Receiving Officer is the Head, Internal Audit Division.
The contact details of the Receiving Officer are as follows:
To: Receiving Officer, Cuscaden Peak Investments Private Limited
Address: Bridge+, 79 Robinson Road, #07-01, CapitaSky, Singapore 068897
Hotline: 6631 8920
4.4. CPI prohibits discrimination, retaliation or harassment of any kind against a whistleblower who submits a complaint or report in good faith. If a whistleblower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the CEO. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.
4.5. At the appropriate time, the party making the report/complaint may need to come forward as a witness. If an Employee or External Party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. If, however, an Employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the External Party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.
4.6. All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.
4.7. CPI reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.
4.8. If, at the conclusion of an investigation, CPI determines that a violation has occurred or the allegations are substantiated, appropriate disciplinary action in accordance with the Fair Employment Policy will be taken. Non-anonymous whistleblowers will be informed that action has been taken at the conclusion of the investigation, without divulging confidential information.
Handling External Media
4.9. In disclosing to external media with regards to alleged misconduct through the whistleblowing channels, CPI will ensure that there is fairness and objectivity in its corporate statements with no misrepresentation and unprofessional pursuit of publicity.
4.10. Where information is confidential, CPI shall not, except in the course of duty or under compulsion by law, disclose, divulge or make public any information of a confidential nature relating to the details of the alleged misconduct.
4.11. During the course of investigation, the whistleblower or any party privy to the confidential information shall not inform external media or any colleagues.
5. ADMINISTRATION – COMMUNICATIONS, TRAINING AND POLICY REVIEW
Communications and Training
5.1. Principles and procedures of the Whistleblowing Policy shall be communicated to all relevant stakeholders at the outset and as appropriate thereafter.
5.2. Employees should read, understand and comply with this policy. All Employees are responsible to ensure the highest standards of ethics, honesty, openness and accountability in line with CPI’s commitment to enhance good governance and transparency, and safeguard the integrity of CPI.
5.3. All relevant Employees shall be trained on the principles of this Policy periodically.
5.4. The Whistleblowing Policy shall be reviewed regularly, where CPI may modify this Policy to maintain compliance with applicable laws and regulations or accommodate organisational changes. This review should be carried out by Head of lnternal Audit.
5.5. CPI’s Internal Audit should review management compliance with this policy and procedure and recommend improvements or updates as necessary towards its continued effectiveness.