Natural Cool Holdings Limited (“NCH”) is committed to a high standard of corporate governance. As one of the elements of corporate governance, this Whistle-blowing Policy (“Policy”) aims to provide a trusted avenue for stakeholders to report fraudulent practices or other improper, unethical conducts within NCH and its subsidiaries (collectively the “Group”). This Policy also aims to ensure that arrangements are in place to facilitate independent investigation and corrective actions on the reported areas.
The Policy is intended to facilitate whistleblowing in the following general areas:
• financial reporting, accounting or other financial matters;
• corruption, misappropriation or blackmail;
• conflicts of interest: when an individual’s personal interest interferes with the interests of the Group;
• breach of confidentiality and misuse of insider information;
• improper use of assets belonging to the Group;
• significant breaches of Group policies or internal controls, including the Code of Conduct and Ethics;
• any criminal offence or failure to comply with a legal or regulatory obligation; or
• concealment of any of the above.
The Policy applies to any employees, vendors/contractors, consultants, customers and other parties whom the Group has a business relationship with. Employees of the Group should highlight matters mentioned above immediately.
Whistle-Blow Reporting & Communication Channels
One should report his/her concern to the Chairman of Audit Committee, who is responsible for handling all reported cases and ensuring that issues raised are properly resolved by the Management or other appropriate parties. The channel of reporting is:
All concerns raised will be independently assessed by the Chairman of Audit Committee to ensure that they are fairly and properly considered. Any individual making a whistle-blowing report will retain his/her anonymity unless he/she agrees otherwise. He/she will also be kept informed of who is handling the matter. All records will be kept strictly confidential by the Chairman of Audit Committee.
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