WHISTLEBLOWING POLICY

Introduction

AGROCROPS is dedicated to upholding the highest openness, integrity, and accountability levels. Ensuring accountability and transparency includes establishing a system that allows employees and other company members to express their concerns responsibly and effectively. It is a fundamental condition in every employment contract that employees faithfully serve their employer and refrain from disclosing confidential information regarding the employer's activities. However, in cases where an individual comes across substantial evidence indicating severe misconduct or wrongdoing within the organisation, it is essential to report this information internally without fear of retaliation. There should be mechanisms to facilitate this reporting independently from the employee's direct management.

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The Public Interest Disclosure Act provides legal safeguards to shield employees from termination or punitive actions by their employers when they publicly disclose specific serious concerns. The Company has adopted the following provisions to guarantee that no staff members face any disadvantages when raising legitimate concerns.

It's important to underline that this policy aims to support individuals who suspect they have encountered wrongdoing or misconduct. Its purpose is not to challenge the financial or business choices made by the Company, nor should it be employed to revisit matters that have already been addressed through harassment, complaint, disciplinary, or other established procedures.

Scope of policy

This policy aims to empower Company employees to raise concerns internally and at a senior level and to share information they believe demonstrates wrongdoing or misconduct. This policy is meant to address concerns that are in the public interest and may, initially, be subject to independent investigation but could subsequently trigger the initiation of other procedures, such as disciplinary actions. These concerns may encompass:

  • Financial malpractice, impropriety or fraud
  • Failure to comply with a legal obligation or statutes
  • Dangers to health, safety, or the environment
  • Criminal activity
  • Improper conduct or unethical behaviour
  • Conducting malpractices in production quality
  • Changing ingredients without proper approval and trials
  • Altering the production line without top management approval
  • Taking money bribes (Cash in kind) and providing supportive quality control reports on supplier goods
  • Attempts to conceal any of these events

Safeguard

Protection: This policy is formulated to provide safeguarding to employees of Agrocrops Singapore Pte. Ltd. and its subsidiaries who report such concerns, as long as the disclosure is made under the following conditions:

  • Made in good faith.
  • Based on the reasonable belief of the individual making the disclosure, it indicates malpractice or impropriety.
  • Disclosed to an appropriate person (see below).

It is essential to note that individuals who opt not to utilise this procedure will not be shielded from internal disciplinary actions. In severe cases, making false or unfounded allegations may result in legal actions being taken by the individuals implicated in the complaints.

Confidentiality: Agrocrops is committed to handling all such disclosures with the utmost confidentiality and sensitivity. The identity of the person making the allegation may be kept confidential, provided it does not impede or obstruct any investigation. During the investigation, the information's source may be uncovered, and the individual making the disclosure may be required to provide a statement as part of the necessary evidence.

Anonymous Allegations: This policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the discretion of the Company. In exercising this discretion, the factors to be taken into account will include:

  • The seriousness of the issues raised
  • The credibility of the concern
  • The likelihood of confirming the allegation from attributable sources

Untrue Allegations: If an individual makes an allegation in good faith that is later found unsubstantiated by subsequent investigation, no adverse action will be initiated against that individual. It is crucial for individuals making disclosures to exercise diligence in ensuring the accuracy of the information they provide. However, if an individual makes false or vexatious allegations, especially if they persist in making such claims, disciplinary measures may be taken against them.

Timescales: Given the diverse nature of these types of complaints, which may involve internal or external investigators and potentially law enforcement, it is not feasible to establish precise timelines for such investigations. However, the investigating officer should make every effort to conduct the investigations promptly, ensuring that the quality and thoroughness of the investigations are not compromised.
As soon as practically possible, the investigating officer should send a written acknowledgement of the concern to the complainant. Subsequently, they should provide a written report to the complainant regarding the investigation's findings and proposed actions. In cases where the investigation extends over an extended period, the investigating officer should maintain regular written communication with the complainant, updating them on the progress of the investigation and the expected conclusion date. All responses to the complainant should be in written form and sent to their home address, clearly marked as "confidential."

Investigating Procedure

The investigating officer should adhere to the following steps:

  • Obtain comprehensive details and seek clarifications regarding the complaint.
  • Notify the member of staff against whom the complaint is made as promptly as practical. The said member of staff will be informed of their right to have a trade union representative or a work colleague accompany them during any subsequent interviews or hearings conducted as per these procedures. Depending on the circumstances and the investigating officer's discretion, an alternative representative, such as the individual's legal counsel, may be permitted.
  • Consider the possible involvement of the Company auditors and the Police at this stage and consult with the Chairman, Chief Executive, or Business Owner as deemed appropriate.
  • Thoroughly investigate the allegations with assistance from other individuals or entities, if necessary.
  • Formulate a judgment regarding the complaint's validity, detailing this judgment in a written report that includes the findings of the investigation and the rationale behind the decision. This report will be forwarded to the Chief Executive, Chairman, or Business Owner, as appropriate.
  • The Chief Executive, Chairman, or Business Owner will determine the appropriate action. If the complaint is substantiated, they will initiate disciplinary proceedings or employ other Company procedures as necessary.
  • Maintain regular communication with the complainant, keeping them informed about the progress of the investigations and, if applicable, the final resolution.
  • If deemed appropriate, utilise the outcomes to facilitate a review of Company procedures.
  • In cases where the complainant is dissatisfied with how the investigating officer handles their concern, they possess the right to raise it in confidence with the Chief Executive, Business Owner, Chairman, or one of the designated individuals mentioned above.

Contact us

To ask questions, seek advice or counsel, or report a potential Code violation, You can confidentially contact the Company Secretary either by letter, or by sending e-mail to grievances@agrocrops.com
Postal Address: AGROCROPS SINGAPORE PTE. LTD., 3 SHENTON WAY, #15-02 SHENTON HOUSE, SINGAPORE-068805

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