WHISTLEBLOWING POLICY AND PROCEDURES
1. INTRODUCTION & PURPOSE
We, MOG GROUP OF COMPANIES and our subsidiaries (collectively referred to as “MOG”, “Group”, “we”, “us” or “our”) are committed to conduct our business with integrity, trustworthiness and accountability.
For this purpose, the Company has developed procedures or mechanisms to facilitate:-
a. reports by Whistleblowers of any suspected or actual Wrongdoings on a confidential basis;
b. investigation of such reports by the Prescribed Officer; and
c. protection against reprisal to Whistleblower who reported in good faith.
This Policy does not replace or affect the Company’s Code of Conduct or other policies and procedures established or to be established by the Company from time to time.
2. REPORTING PROCEDURES
2.1 WHO CAN DISCLOSE
Any of the following persons (“Whistleblower”) can make a report to the Company of any suspected or actual Wrongdoing committed:
- the Group’s employees, including employees on contract, temporary or short-term employees and employees on secondment;
- the Group’s third-party service providers, independent contractors, vendors and suppliers; and
- members of the public.
2.2 WHAT TO DISCLOSE
A report can be made if it relates to any conduct which if proved, constitutes a disciplinary offence or a criminal offence by any employee or director within any Group company (“Wrongdoing”).
Wrongdoing includes, but is not limited to: –
- taking or giving favours, kickbacks, bribes and privileges
- corruption or fraud
- misappropriation of funds
- misuse of funds or assets
- theft or embezzlement
- gross mismanagement
- abuse of power by any director or officer of any Group Company
- serious financial irregularity or impropriety
- serious breach of Company’s Code of Conduct
– act, omission, misrepresentation or concealment of information which lead to, cause or create a substantial or specific danger to the lives, health, or safety of the Group’s employees, the public or the environment;
– failure to comply with provisions of laws, regulations and directives where the wrongdoer knowingly or intentionally disregards compliance with such provisions;
- disciplinary offence or criminal offence
– knowingly directing or advising a person to commit any of the above Wrongdoing.
Wrongdoing excludes matters which are :-
– trivial or frivolous in nature; and
– motivated by malice.
If an employee is unsure whether a particular act or omission constitutes a Wrongdoing under this Policy, that employee is encouraged to seek advice or guidance from his or her immediate superior or head of department or supervising director.
Read more here – Whistleblowing Policy & Procedures