Scicom's Whistleblowing Policy

Policy Statement

SCICOM is committed to promote and maintain high standards of transparency, integrity, accountability and ethics as well as good Corporate Governance practices in the conduct of its businesses and operations.

In line with these core values, SCICOM has made available an avenue for all employees and members of the public to disclose any improper conduct or malpractice committed or about to be committed to/within SCICOM Group at the earliest opportunity and to provide protection to persons making such disclosure.

 

Scope of the Policy

The scope of whistleblowing under this Policy includes:

  • Incidents of fraud, corruption or bribery;
  • Money laundering;
  • Abuse of power;
  • Conflict of interest;
  • Theft or embezzlement;
  • Misuse of Company’s property or information;
  • Breach of applicable laws and regulations;
  • Breach of SCICOM’s policies, procedures and other codes of conduct;
  • Situations which pose a danger to health, safety or any individual or significant danger to the environment;
  • Any other wrongdoing the nature of which is subject to SCICOM’s absolute discretion.

This Policy does not apply to employment issues which are to be dealt with in accordance with SCICOM’s Employee Grievance Procedure.

 

Whistleblowing Procedure

All disclosures are to be made in accordance with the SCICOM Whistleblowing Procedure as provided under this Policy.

 

Anonymity of Whistleblower

A Whistleblower is encouraged to identify himself/herself and provide contact information in his/her disclosure. Anonymous disclosures may impede an investigation and prevent SCICOM from providing the Whistleblower with the necessary protection as the Company will not know who you are.

Irrespective of this, anonymity will be maintained as permitted by law or the Whistleblower indicates that he/she no longer wishes to remain anonymous.

 

Protection to Whistleblower

A Whistleblower will be accorded the protection of confidentiality, to the extent reasonably practicable and as permitted by law. In addition, a Whistleblower who is a SCICOM employee will be protected against any adverse or detrimental actions as a result of making a disclosure under this Policy. Such protection is accorded even if the investigation later reveals that the Whistleblower was mistaken as to the facts, the rules or procedures involved.

 

Withdrawal of Disclosure Made

A Whistleblower may request the withdrawal of his/her disclosure. Such request shall be in writing in accordance with the SCICOM Whistleblowing Procedure.

SCICOM reserves the right to proceed with investigation of a disclosure even if it is subsequently withdrawn by the Whistleblower.

 

Investigation and Reporting

All disclosures will be investigated promptly by a person/party as directed by SCICOM’s Audit and Risk Management Committee (‘ARMC’). The ARMC has the authority to:

  • Determine the legitimacy of a disclosure received;
  • Direct further action;
  • Ensure all reasonable steps have been taken for a fair and unbiased investigation regarding a disclosure; and
  • Decide on the necessary action to be taken based on recommendation outlined in the investigation report.

 

Notification

The Whistleblower will be notified of the outcome of his/her disclosure.

 

This Policy may be amended from time to time.

 

Scicom's Whistleblowing Procedure