Whistle Blowing Policy

January 2021

1. Definition

Whistle blowing is the act of reporting of alleged unethical conduct of employees, management, directors and other stakeholders by an employee or other person(s) to appropriate authorities.

The whistle blowing policy aims to create an environment where employees, vendors, service providers, clients 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.

Employers and employees are key stakeholders and therefore expected to play a vital role in deterring and detecting malpractices, wrongdoing or irregularity. The process of whistle blowing can be initiated either internally or externally. Employees are internal whistle blowers who report incidents of misconduct in an organization involving a peer/colleague, a supervisor or indeed a top management official. On the other hand, external whistle blowers who are mostly customers/suppliers report wrong doings of employees to the Head of Internal Auditor and/or the Managing Director/Chief Executive Officer respectively.

This policy aims to abate the fear of reprisal by way of harassment or victimization at the hands of the Zedcap Partners Limited (“ZPL” or the “Company”) or the group of people accused.

2. Objectives

a. To provide a safe avenue for escalating suspected misconduct without fear of reprisal;
b. To serve as a tool for the identification of risk events;
c. To enforce ZPL’s zero tolerance to fraudulent, illegal and unethical conduct
d. Reportable Misconduct
e. Conduct that is against ZPL’s code of conduct, rules, procedures, and policies, or established standards of practice;
f. Conduct that amounts to fraudulent or illegal act as defined within ZPL’s Anti-Money Laundering Policy, including theft and corrupt practices;
g. Unethical conduct according to the ZPL’s Code of Conduct & Ethics and its Anti- Bribery Policy;
h. Conduct that amounts to misuse of ZPL’s resources, including business information;
i. Conduct that amounts to willful or negligent instances of non-performance of duties, including abuse of office;
j. Health and safety violations;
k. Conduct that amounts to an attempt to conceal any of these actions.

3. Commitment to the Policy

Zedcap partners Limited is committed to the highest standards of ethics, honesty, openness and accountability. In line with this commitment and in order to enhance good 2 Governance, transparency and safeguard the integrity of our organization, this Whistle blowing Policy is intended to provide:

a. An avenue for raising concerns related to any illegal or unethical behaviour such as fraud, corruption and other misconduct;
b. Assurance that those who disclose such information will be adequately protected, and that action would be taken on the disclosure; and
c. The accused will be given a fair hearing and representation as the case may be.

The Board of Directors and Management of ZPL is committed to promoting a culture of openness, accountability and integrity, and will not tolerate harassment, victimization or discrimination of the whistle blower, provided such disclosure is made in good faith with reasonable belief that what is being reported is true. Therefore, employees, stakeholders, client and members of the public can raise legitimate concerns, without fear of and are given assurance that such concerns would be adequately addressed.

ZPL’s whistle blowing policy is therefore fundamental to our professional integrity. In addition, it reinforces the value placed on employees to be honest and respected members of their individual professions. It provides a method of properly addressing bona fide concerns that individuals within the organization might have, while also offering whistleblower’s protection from victimization, harassment or disciplinary proceedings.

Whilst the Company encourages disclosure of identity by the whistleblower, where possible, it also appreciates disclosure under anonymity with re-assurance that such identity would be protected at all stages in any internal matter, except with the consent of the individual or in circumstances where ZPL is unable to resolve the concern without revealing such an identity: for instance, if external legal action flows from the disclosure and the employee’s evidence is required in court.

If an allegation is made in good faith but not confirmed by subsequent investigation, no action will be taken against the person concerned.

4. Confidentiality

All information obtained from a Whistleblowing Report would be considered Confidential and will not be disclosed or discussed with other persons, except for the purpose of an investigation or where the Company has a legal or regulatory obligation to disclose.

Any breach of this Confidentiality would be treated in accordance with the Disciplinary Process as stipulated within the ZPL Staff Hand Book.

5. Whistleblower Protection

ZPL has an obligation to adequately protect the whistleblower. Therefore, reprisal against any employee/Client who in good faith reports a concern about illegal or unethical conduct will not be tolerated. ZPL is also committed to maintaining confidentiality to the fullest extent possible and provides assurance that all reports will be subject to appropriate investigation and conclusion through an efficient process.

Therefore, whistleblowers are encouraged to disclose their names when filing reports to enhance credibility. However, anonymous disclosures may be considered on the following discretionary basis:

a. The seriousness of the issue(s);
b. The significance and credibility of the concerns; and
c. The possibility of confirming the allegation.

Whistleblowers, either internal or external, may be rewarded depending on the gravity of the case. Compensation may also be provided to whistleblowers who may have suffered loss in the course of the process. This is however at the discretion of the Board of Directors.

6. Whistleblowing Channels

a) Internal Audit – audit@zedcrestcapital.com
b) ZPL Websites – (www.zedcappartners.com; www.zedcrest.com);
c) Dedicated Phone line – 01-6311666

7. Minimum Information Required for a Whistleblowing Report

a. Name of officer(s) involved
b. Nature of Misconduct (Fraudulent/Illegal Conduct, Unethical Conduct, Internal Procedural Breach, Regulatory Compliance Breach, Obstruction of internal/external regulators & auditors, Health & Safety Risks, Abuse of Office, Misuse of Company Resources, Wilful Negligence, Etc)
c. Date of Occurrence
d. Estimated value of loss to the Company (if any)
e. Specific evidence of occurrence of the Misconduct

8. Confidential & Anonymous Whistleblowing

a. Confidential Whistleblowing: A whistleblower is encouraged to reveal his or her identity when a report or disclosure is made using any of the channels mentioned above. This approach helps the investigation significantly, as the Whistleblower can be contacted to provide further details on the report, where necessary.

b. Anonymous Whistleblowing: However, a whistleblower may choose not to reveal his or her identity upon making a report. With the reporter’s anonymity thus assured, the identity of the reporter cannot be ascertained by anyone. Should this approach be chosen, the Whistleblower must ensure that enough information is provided to enable a thorough investigation.

9. Investigation

Instances of suspected fraud and corrupt activities shall be investigated in accordance with ZPL’s Anti-Money Laundering Policy. The Internal Audit Unit shall ensure the report is properly investigated and adequately addressed.

The whistleblower may seek follow-up information about the investigation of a report, escalated using the confidential whistleblowing option, or any consequent action taken by ZPL.

This Policy was re-approved by the Board in January 2021 and became effective as of that date.