Purpose

 

The YuuZoo Group is committed to maintaining an ethical culture, one of integrity and compliance with laws, regulations and industry standards. The Group does not tolerate its staff undertaking any impropriety, wrongdoing, malpractice, or statutory non-compliance in the course of their work. This policy for whistleblowing (the “Policy”) is intended to provide a channel for the reporting of actual or suspected wrong- doings committed by YuuZoo Group staff, contract staff  or  contractors  for  investigation  and  corrective action without fear of adverse consequences.

 

Scope

 

Employees and outside parties, such as customers, suppliers, shareholders and members of the public, may use the procedures set out in the Policy to report any concern regarding:

 

  • Questionable accounting practices
  • Serious breaches of the Group’s policies
  • Conflicts of interest, issues with compliance or internal controls
  • Forgery
  • Misappropriation of funds and classified documents
  • Abuse and/or misrepresentation of power and authority
  • Failure to comply with laws and regulations
  • Insider trading
  • Anti-competitive behaviour
  • Discrimination on the basis of gender, race, disabilities
  • Bullying, harassment or other employee misconduct
  • Unsafe work practices
  • Corruption and bribery
  • Theft, violence and/or assault

 

The Policy implements a framework to protect genuine whistleblowers from punishment, discrimination or adverse consequences, and also permits the Group to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible. The Group will disregard Bogus and/or frivolous complaints, and otherwise complaints related to personal grievances. Personal grievances should be addressed to division or department heads directly.

 

Reporting Channels

 

Wherever possible, the whistleblower is encouraged to put his their name to the allegations. It is difficult to effectively act upon anonymous reports. Nonetheless, the Group will give due consideration to anonymous reports, taking into account the credibility and seriousness of the issues raised, and the likelihood of confirming the allegation from information provided and other attributable sources. Every effort will be made to ensure that confidentiality is maintained throughout the process of addressing whistleblowing reports.

 

While reports may be raised verbally or in writing, in order to adequately investigate a complaint, it is essential for the Group to have as much detail as possible. Such detail should include the specific concerns, parties  involved,  the  period  of  time  and/or  dates,  evidence  substantiating  the  complaint,  and,  where possible, and contact details of the whistleblower. Reports should be directed to a whistleblowing officer (“Officer”). The contact details of the Officer of the Group below:

 

 

Reports directed to other parties within the Group will be directed to an Officer. The Officer  is  responsible for maintaining a centralised repository of all reported cases and ensuring that all genuine cases are properly resolved. The Officer will review all reports within a reasonable time frame, and after due consideration and inquiry, will take a decision on whether to proceed with a detailed investigation. Guidance/direction may be sought from the CEO or the Legal Department and other appropriate parties. All reports alleging fraud and breaches of corporate governance will be escalated to the Chairman of the  Board.

 

Further, where the complaints relate to a senior executive and/or the CEO, the relevant Officer will escalate these directly to the Chairman of the Board, who will then decide whether to report the matter to the Board. Other than those complaints which are escalated directly to the Chairman of the Board, the CEO will determine the cases to be escalated to the Board.

 

In the unlikely event that a whistleblower believes that they are being subjected to discrimination, retaliation or harassment for having made a report under this Policy, they should immediately report those facts to the Officer or the Legal department, as appropriate.

 

Addressing Reports

 

At the appropriate time, the party making the report/complaint may need to come forward as a witness. Where a party makes a good faith allegation, but such allegation it is not confirmed by the investigation, no action will be taken against such party. Nonetheless, if an employee makes a frivolous or malicious allegation, or otherwise, an allegation for the purposes of personal gain, disciplinary action may be taken. Likewise, if investigations reveal that an external party has made a malicious allegation, or an allegation for the purpose of personal gain, appropriate action, including reporting the matter to the police, may be taken.

 

The Officer may, in consultation with the CEO and/or senior management, direct the report to the division/department best placed to address it, or lead the investigation to ensure prompt and appropriate investigation and resolution. All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

 

Depending on the nature of the complaint, the subject of the report may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal. The Group reserves the right to refer any concerns or complaints to appropriate external regulatory authorities.

 

If, at the conclusion of an investigation, YuuZoo determines that a violation has occurred or the allegations are substantiated, effective remedial action commensurate with the severity of the offence will be taken.

 

Modification

 

YuuZoo may modify this Policy from time to time without notice to maintain compliance with applicable laws and regulations or accommodate organisational changes within YuuZoo.

 

Last Updated 15 March 2017