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Whistleblower protection system
Whistleblower protection scheme is one of the key plans within the framework of business ethic undertakings of the Company. The scheme aims at creating a safe and reliable environment for any internal and external stakeholders of the Company so that they could speak out and report any non-compliance without the worry of being retaliated. This scheme has the support from an independent audit committee and internal audit department to make sure that the management will take appropriate measures to resolve any noncompliance and protect the privacy and safety of the whistleblowers.
The Company acknowledges honest and sincere business culture. We hope that our employees possess the competence and confidence to raise and report any risk-related concerns, which include but not limited to the concern of risk involving business ethics, legal compliance, environment, society and governance. Everyone (whether or not being employed by SITC) are welcome to raise questions and doubts, and various contact channels are available. Employees could have discussion with their direct superior or the Company’s management members, access to professionals or auditors, or anonymously report through special mailbox. Anonymous report through telephone or internet will also be accepted.
1. Undertaking of Whistleblower Protection
The Company has made public undertaking to protect the identity and privacy of all whistleblowers and will ensure that all whistleblowers could freely exercise their rights without being inappropriately interfered or suppressed. We assure our employees that, regardless of the occurrence of the non-compliance, they will not be disadvantaged due to whistleblowing. This is also applicable to our business partners who wish to report any potential violation. In this regard, we will take necessary measures to make sure the whistleblowers will not be retaliated or inappropriately treated.
Internal and external whistleblower protection policy and mechanism will be publicly informed by the Company to our employees and business partners such as external suppliers, and regular announcement in relation to the status of the internal and external whistleblower protection mechanism will be made, so that our employees and external parties could understand the effectiveness and reliability of, and comply with the mechanism.
2. Policy of Retaliation Prohibition
We have zero tolerance to any form of retaliation to any whistleblowing on goodwill or to any employee coordinating with the whistleblower in the investigation. Any form of retaliation to any whistleblower is strictly prohibited, which includes but not limited to dismissal, demotion, salary decrease, removal, threatening or intimidation. Any retaliation discovered will be stopped by appropriate measures, and disciplinary sanction will be imposed on any person who is in breach of the Company’s policy.
3. Safe Whistleblowing Procedure
Anonymous and real-name whistleblowing channels are provided by the Company to help whistleblowers report any act which has violated the law, ethics or the Company’s policies. The Company will also ensure the confidentiality and safety of the whistleblowing channels. Necessary measures will be taken to protect the identify and personal information of any anonymous whistleblower from being disclosed. Meanwhile, the Company will take any necessary measures to ensure that the real-name whistleblowers will not be violated or retaliated.
4. Whistleblowing Handling Procedure
The Company will ensure proper handling of the reporting content of the whistleblowers and provide immediate response thereto. Apart from general whistleblowing, any serious and suspicious case will be handled and fully investigated through appropriate measures.
For any case in which disclosure of the identity and personal information of the whistleblower is need, e.g. auditors or investigators need to have understanding of the proof and information provided by the whistleblowers during investigations, the Company will take necessary measures to protect their privacy to ensure that the whistleblowers will not be violated or retaliated.
At the same time, the Company will strictly abide by all relevant laws and regulations, and take all necessary measures to protect the interests of the Company. The Company will investigate all dishonest or malicious whistleblowing and impose disciplinary sanction.
5. Whistleblower Protection Mechanism
A special whistleblower protection mechanism will be set up by the Company to provide