Whistleblowing Policy

Updated: 30 September 2024

Purpose

Sun Venture Pte. Ltd. (“SVPL”) is committed to maintaining high standards of ethics and integrity in its business conduct and operations. Consistent with the firm’s “zero tolerance” stance to fraud, bribery, corruption and other unethical behaviour or conduct, SVPL has adopted this Whistleblowing Policy (“Policy”).

The Policy aims to:

  • provide an avenue for employees, vendors, customers and other stakeholders
    to report genuine concerns, particularly in relation to fraud, controls or ethics, without fear of reprisals when whistleblowing in good faith; and
  • ensure that robust arrangements are in place to facilitate independent investigation of the reported concern and for the appropriate follow up actions to be taken.

Reportable Incidents

Examples of genuine concerns covered by this policy include but are not limited to:

  • misconduct relating to financial reporting, accounting or other financial matters;
  • corruption, misappropriation or blackmail;
  • abuse of power by an employee;
  • any criminal offence or failure to comply with a legal or regulatory obligation;
  • significant breaches of SVPL policies or internal controls;
  • actions detrimental to health and safety or the environment;
  • discrimination under the basis of gender, race, disabilities;
  • concealment of any of the above.

Confidentiality

The identity of a whistleblower who raised a concern in good faith will be kept confidential and will only be disclosed on a strictly need-to-know basis.

Exceptional circumstances under which information provided by the whistleblower could or would not be treated with confidentiality include:

  • Where SVPL is under legal obligation to disclose the information provided.
  • Where the information is already in public domain.
  • Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice.
  • Where the information is given to the enforcement agencies for criminal investigation.

Protection Against Reprisal

SVPL is committed to creating an environment where employees and stakeholders feel safe and supported when reporting concerns. SVPL will not tolerate the harassment or victimisation of anyone reporting a genuine concern. Furthermore, no person should suffer reprisal as a result of reporting a genuine concern, even if they are mistaken.

While the Policy is meant to protect the whistleblower from any unfair treatment as a result of his report, this assurance does not extend to any person who intentionally provides frivolous, malicious or untrue complaints and may result in disciplinary actions.

Disciplinary actions will be taken against anyone who subjects a whistleblower who makes a report in good faith to any form of reprisal.

Whistleblowing Reporting & Communication Channels

The individual should report any concerns or suspicious unethical, illegal, or improper conduct directly to the Head of Risk Management & Compliance (“RMC”), who is responsible for handling all reported cases and ensuring that issues raised are properly resolved.

An Investigation Advisory Committee (“IAC”), comprising the Head of RMC, Head of Human Capital Management (“HCM”), and representatives from RMC and HCM is formed to investigate and review each reported case. The IAC reports to the Chairman of SVPL and submits a report of the findings and recommendations on actions to be taken upon the conclusion of each investigation. The whistleblower identity will not be included in the report. The Chairman of SVPL shall determine the final remedial actions to be taken. In the event when any member of the IAC is unable to take part in the investigation due to conflict of interests, the member will be excused from the case review and will not be privy to the details of the reported case. In such situation, the Chairman can appoint a third party, a Head of Department who is not in the IAC to be part of the investigation.

All concerns raised will be holistically assessed to ensure that they are fairly and properly considered. As it is essential to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much information and be as specific as possible.

Concerns expressed anonymously are difficult to act upon effectively; however, they may be considered, taking into account the following:

  • Seriousness of the issues raised;
  • Significance and credibility of concerns;
  • Likelihood of confirmation of the allegation from attributable sources and information provided.

Hence, the whistleblower is encouraged to provide his / her contact information so that clarifications could be sought during the course of investigation. If a whistleblower chooses to make such reports anonymously, he / she shall not be entitled to the investigation outcome of the case reported.

The channel of reporting is through email to whistleblowing@sunventure.com