Whistleblower Protection Policy

Definition

  • GCCP requires directors, officers and employees to observe highest standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the GCCP, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws, regulations and moral and social standards.
  • Pursuant to the Singapore Code of Corporate Governance, the Audit Committee of the Company shall have the overall authority and oversight of this Policy from time to time. The Audit Committee may in its absolute discretion delegate the investigation of the whistle-blowing reports and implementation of this Policy.

Reporting Responsibility

  • This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that GCCP can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of GCCP’s code of ethics or suspected violations of law or regulations that govern GCCP’s operations.
  • This Policy applies to any suspected improprieties involving employees as well as consultants, vendors, contractors, and/or any other parties with a business relationship with the GCCP Group of Companies.
  • Reporting of all irregularities and complaints can be forwarded to the following channels:
    Email : ianlim@gccpresources.com
    Postal address :
    Chief Financial Officer (Compliance Officer)
    GCCP Resources Ltd.
    D21-1, Menara Mitraland
    13A, Jalan PJU 5, Kota Damansara
    47810 Petaling Jaya , Selangor, Malaysia.
  • Reporting of improprieties against any Director or member of the Senior Management (having designation of Chief Executive or Executive Director and above) may be reported directly to the Chairman of the Board and the Chairman of the Audit Committee using the following email communication channels:
    Chairman of the Board: chairman@gccpresources.com
    Chairman of the Audit Committee: acchairman@gccpresources.com

Protection Against Reprisals

  • It is contrary to the values of GCCP for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of GCCP.
  • An employee who retaliates against someone who has reported a violation in good faith is subject to disciplinary action up to and including termination of employment.
  • However, GCCP does not condone frivolous, mischievous or malicious allegations. Employees or external parties making such allegations may face disciplinary action.

Reporting Procedure

  • GCCP has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with a person above your supervisor or any of the Executive Officer, Executive Director, or a board member.
  • Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the GCCP’s compliance officer or designated employee or board member, who has the responsibility to investigate all reported complaints.
  • Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Executive Officer, Executive Director or the organization’s Compliance Officer.
  • The GCCP’s Compliance Officer or any designated person is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the Executive Director and/or the Board of Directors of all complaints and their resolution and will report at least annually to the Chairman of the Audit Committee on compliance activity relating to accounting or alleged financial improprieties.
  • When making a complaint, the following information should be provided:
    -Date, time and place of the actions/transactions
    -Identity and particulars of parties involved
    -Circumstances leading to the improprieties
    -Any other relevant information or documentation that would assist in the evaluation of the report.
  • Accounting and Auditing Matters – Any suspected irregularities concerning accounting practices, internal controls and auditing matters shall immediately be reported to the Audit Committee. The committee will start an investigation and work to resolve the matter immediately.

Confidentiality

  • GCCP encourages the whistleblower to identify himself/herself when raising a concern or providing information. All concerns will be treated with strict confidentiality.
  • Exceptional circumstances under which information provided by the whistleblower could or would not be treated with strictest confidentiality include:
    o Where GCCP is under a legal obligation to disclose information provided
    o Where the information is already in the public domain
    o Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice
    o Where the information is given to the Police or other authorities for criminal investigation
  • In the event GCCP is faced with a circumstance not covered by the above, and where the whistleblower’s identity is to be revealed, it will endeavor to discuss this with the whistleblower first.

Concerns and Information Provided Anonymously

  • Concerns expressed anonymously are much less persuasive and may hinder investigation work as it is more difficult to look into the matter or to protect the whistleblower’s position. Accordingly, GCCP will consider anonymous reports, but concerns expressed or information provided anonymously will be investigated on the basis of their merits.

Handling of Reported Violations

  • The GCCP’s Compliance Officer will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
  • Compliance Officer: * (Note: The Compliance Officer may be a board member, the Executive Director, or a third party designated by the organization to receive, investigate and respond to complaints.)
  • All whistle-blowing reports, other than reports involving any Director, member of the Senior Management, shall be received by the Compliance Officer or designated person who will log all reports into a register.
  • The designated officer shall conduct an initial review of the report received and the action taken by the Company will depend on the nature of the concern. All investigations shall be reported to the Audit Committee for their attention and further action as necessary. The matters raised may:
    -be investigated internally
    -be referred to external auditor
    -be referred to appropriate law enforcement agencies
    -be investigated by an independent inquiry

Suspected Improprieties

  1. Forgery or any act of fraudulent
  2. Misappropriation of funds and classified documents
  3. Abuse and misrepresentation of power and authority
  4. Failure to comply with laws and regulations
  5. Discrimination on the basis of gender, race, disabilities
  6. Harassment
  7. Corruption and bribery
  8. Theft
  • This Policy does not and cannot reasonably detail or cover every situation that should be reported. If you are in any doubt as to how you should apply any provisions of this Policy, at any point in time, you are strongly encouraged to seek guidance from your immediate supervisors, the Company’s Senior Management or the member of the Audit Committee.

Implementation of the Policy

  • A copy of the Policy shall be made available on the Company’s website for transparency and ease of access by all employees and any parties who have business relationship with the Company.
  • This Policy will be briefed to all new employees as part of their orientation program.
  • Regular communications shall be made to stress to all employees the importance of this Policy as well as to maintain awareness of the Board’s continued commitment to this Policy.
  • The designated Compliance Officer shall collate any feedback received and report to the Audit Committee on a periodic basis.
  • The designated Compliance Officer shall be responsible for maintaining, reviewing and updating this Policy. Any proposed revisions shall require the Audit Committee’s approval.