Whistleblowing policy

1. About this policy

1.1 We are committed to conducting our business with honesty and integrity,and we expect all staff to maintain high standards in accordance with our Code of Conduct. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct.

1.2 The aims of this policy are:

i. To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
ii. To provide staff with guidance as to how to raise those concerns.
iii. To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

1.3 This policy covers all employees, officers, consultants, contractors, casual workers and agency workers. It does not form part of any employee’s contract of employment, and we may amend it at any time.

2. Personnel responsible for the policy

2.1 The Audit Committee has overall responsibility for this policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this policy.

2.2 The Whistleblowing Officer has day-to-day operational responsibility for this policy, and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training. The Whistleblowing Officer, in conjunction with the Audit Committee should review this policy from a legal and operational perspective at least once a year.

2.3 All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Whistleblowing Officer.

3. What is whistleblowing?

3.1 Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

i. criminal activity;
ii. failure to comply with any legal obligation or regulatory requirements;
iii. danger to health and safety;
iv. modern slavery
v. damage to the environment;
vi. bribery under our Anti-corruption and Bribery Policy;
vii. financial fraud or mismanagement;
viii. breach of our internal policies and procedures;
ix. negligence;
x. the deliberate concealment of any of the above matters.

3.2 A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

3.3 This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the grievance procedure. If you are uncertain whether something is within the scope of this policy you should seek advice from the Whistleblowing Officer, whose contact details are at the end of this policy.

4. Raising a whistleblowing concern

4.1 We hope that in many cases you will be able to raise any concerns with your line manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. In some cases, they may refer the matter to the Whistleblowing Officer.

4.2 However, where the matter is more serious, or you feel that your line manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact one of the following using the details are set out at the end of this policy:

  • The independent ProActive Hotline reporting service operated by accountancy firm Grant Thornton;
  • The Whistleblowing Officer;
  • The Group company secretary;
  • The chairperson of the Group’s audit committee.

4.3 We will arrange an opportunity with you as soon as possible to discuss your concern. We will take down a written summary of your concern and provide you with a copy after the discussion or meeting. We will also aim to give you an indication of how we propose to deal with the matter.

5. Confidentiality

5.1 We hope that staff will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.

5.2 We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible.

6. Investigation and outcome

6.1 Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information.

6.2 In some cases, we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

6.3 We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

6.4 If we conclude that a whistleblower has made false allegations maliciously, the whistleblower will be subject to disciplinary action.

7. If you are not satisfied

7.1 While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.

7.2 If you are not happy with the way in which your concern has been handled, you can raise it with one of the other key contacts in paragraph 4, including the chairman of the Audit Committee. Contact details are set out at the end of this policy.

8. External disclosures

8.1 Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. We encourage you to report such concerns internally first. You should contact your line manager or one of the other individuals set out in paragraph 4 for guidance.

9. Protection and support for whistleblowers

9.1 It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.

9.2 Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Whistleblowing Officer immediately. If the matter is not remedied you should raise it formally using our grievance procedure.

9.3 You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action.

10. Contacts

ProActive Hotline

Phone number/ SMS/ WhatsApp: +62 812 8250 5042

Email: wb@evansproactive.com

Website: https://proactivehotline.grantthorntonsolutions.ph/report/pt-evans-indonesia

Postal address:
PT Evans Indonesia ProActive Hotline
c/o Grant Thornton Indonesia
Sampoerna Strategic Square, South Tower Level 25
Jl.Jend.Sudirman No.3/RW.4
Karet Semanggi, Kecamatan Setiabudi, Kota Jakarta Selatan
Daerah Khusus Ibukota Jakarta 12930

Whistleblowing Officer
Luke Shaw

Group Company secretary
Katya Merrick

Chair of the Audit committee
Bruce Tozer


October 2023

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