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Company Whistleblowing Policy

Whistleblowing

Asiaphos Limited (AP)’s whistleblowing Framework provides a platform for individuals to disclose any observed improprieties that involve Asiaphos Limited’s employees and/or business partners, without fear of reprisal.

All instances of whistleblowing will be independently reviewed and investigated by an Investigative Committee led by Asiaphos Limited’s Audit Committee Chairman.

Whistleblowers should report their concerns in good faith. The whistleblower’s identity and the concerns raised will be kept confidential, unless as required by the law to reveal to parties such as lawyers, the police or investigators.

Types of Improprieties

Reportable improprieties include the following (non-exhaustive):

  1. Corruption/bribery  is the receiving, asking for, offering, promising or giving any gratification to induce a person or be induced to do a favour with a corrupt intent. Types of gratification include but not limited to money, sexual favours, properties, promises and services. Favours could come in the form of seeking confidential information, leniency, special privileges and contracts.
  2. Fraud  is any illegal act characterized by deceit, concealment, or violation of trust. They are perpetrated to obtain money, property or services; to avoid payment or loss of services; or to secure personal or business advantage. Common examples of fraud include asset misappropriations, forgery and misuse of information acquired in the course of employment.
  3. Unlawful Conduct includes all forms of illegal behaviour such as drug sale or use, violence or threatened violence, criminal damage against property, sexual harassment, money laundering, and terrorism financing. 
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