(CASA Holdings Limited and its subsidaries)
1.1 Submission of incidents or concerns
All employees (including Full time, Part time and contract employees) in the group should forward incidents or concerns on a confidential or anonymous basis using the following channel.
a) By email or writing directly to the Chairman of the Audit Committee ("AC"), in a sealed envelope marked "Confidential" and addressed to:
Chairman of the Audit Committee
Casa Holdings Limited
15, Kian Teck Crescent
Email to: email@example.com
To assist the "Whistle Blowing Committee" in assessing and investigating the reported incidents or concerns effectively and efficiently, employees should specify as much specific and factual information as possible so as to allow for proper evaluation of the nature, extent, validity and urgency of the matter reported.
At the minimum, the following key information should be provided (where applicable):
a) The alleged event, matter of issue that is the subject of concern;
b) The name(s) of the person(s) and/or the Department and/or subsidiary involved;
c) The date and place in which the event has taken place; And additional information, documentation or evidence available to support the matter, event or issue reported.
1.2 Assessment, investigation and treatment of incidents or concerns
Factors to consider in determining whether to conduct an investigation
Upon the receipt of an incident or concern, the Committee shall record it and assess the nature, extent, validity and urgency of the reported matter.
In determining whether the reported matter requires an investigation, the Committee shall assess the following factors, among other factors appropriate under the circumstances.
a) Who is the alleged "wrongdoer"?
If a senior management is alleged to have engaged/involved in the alleged wrongdoing, this factor alone may influence the decision in favour of conducting an investigation.
b) How serious is the alleged wrongdoing?
If the alleged wrongdoing would constitute a crime either involving the integrity of the financial statements of CASA, misappropriation of assets or violation of any laws and regulations, this alone may influence the decision in favour of conducting an investigation.
c) How credible is the allegation?
In assessing credibility, the Committee will consider all facts surrounding the allegations (where available), including but not limited to whether similar allegations have been made in the press.
Reporting of incidents or concerns
Due to confidentiality, the Committee shall table to the AC during its quarterly meetings only the number of reported cases. The full report will be submitted under confidential cover to the AC. For serious reported incidents or concerns, the Committee shall submit its report under confidential cover to the AC via circulation or through a special AC meeting arranged as soon as possible.
Response to incidents or concerns reported
Writing who have identified themselves will usually receive a response to their allegations within two working weeks. The time required for the investigation will depend on the nature, severity of the case and the parties involved.
Use of experts or advisors in an investigation
The Committee may, in its discretion, engage the assistance of one or more experts/advisors (such as outside legal counsel, external or internal auditors, subject matter experts etc) to assist in the investigation and/or analysis of the results.
Treatment of the reported incident or concern after investigation
Following an investigation, if the alleged incident or concern is determined to be valid, the Committee shall write and issue a formal report to the AC within two working weeks after the completion of the investigation. The Report shall clearly indicate:
a) The name of the people involved in the incident, including any external parties.
b) The role of each of the people involved in the incident, including external parties (where applicable).
c) The nature of event that took place
d) The circumstances of the events leading to the incident.
e) A quantification of the extent of the financial implication involved (where possible including reputation and/or financial loss).
f) Recommended remedial and corrective actions to be taken including disciplinary actions in accordance with CASA's Human Resource Policy such as dismissal or reporting of the case to the legal authorities.
The AC shall review the Report, advise and authorize the Committee of an appropriate action to be taken against the investigated incident.
2. Protection of whistle blowers
The Committee shall ensure the strict confidence of all reported incidents and ensure the confidentiality and anonymity of the Employees reporting the incidents or concerns to the fullest extent reasonably practicable within the requirements of the law.
The Committee shall not retaliate, and shall not tolerate any retaliation by management or any other persons or groups directly or indirectly, against any Employees who in good faith reports an incident or concern within the scope of this policy, including providing assistance to the Committee, Management, AC, any governmental, regulatory or law enforcement body/agency in the investigation of the reported incident.
The Committee shall not make any efforts or tolerate any efforts made by any other persons or groups to ascertain the identity of the Employees who reports an incident anonymously.
The Committee shall not, unless compelled by judicial or other legal process/authority, reveal the identity of the Employees who reports an incident or concern under the scope of this policy.
However, any Employees who does not act in good faith or makes an allegation without having reasonable grounds for believing it to be substantially true, or makes it for purposes of personal gain, or makes it maliciously, may be subject to disciplinary action, as the intentional filing of a false report, is itself considered an improper behaviour which CASA has the right to act upon. Nonetheless, should an allegation be made in good faith but it is not confirmed by subsequent investigation, no action will be taken.
3. Retention of records
The Committee shall maintain a log of all reported incidents or concerns, tracking their receipt, investigation and resolution.
The Committee shall also maintain records of all steps taken in connection with any investigation conducted of a reported incident including investigations which are subsequently found to be unsubstantiated.
All records of the Committee and the advisors/experts it utilizes in connection with an investigation and response to the reported incident (including the above mentioned) shall be retained by Casa, Human Resource