Whistle Blowing Policy

1. Introduction

Dr. Ko Holdings (“the Group”) and its subsidiaries are dedicated to maintaining the highest standards of professionalism and ethical conduct among its employees. The Whistleblowing Policy (“Policy”) is established to provide a confidential channel for employees and third parties to report in good faith any concerns related to wrongdoings, malpractice, or irregularities within the organization.

2. Scope of Policy

This Policy applies to all individuals associated with the Group and covers complaints related to, but not limited to:

i. Unlawful acts breaching criminal or civil law, including sexual harassment.
ii. Bullying.
iii. Breach of Company policies and procedures, including unauthorized sharing of proprietary information.
iv. Financial malpractices.
v. Impropriety and fraud.
vi. Corruption, bribery, and blackmail.
vii. Criminal offenses.
viii. Actions capable of causing physical harm to others.
ix. Actions posing a risk of damage to Company assets.
x. Falsification or destruction of financial records.
xi. Misrepresentation of financial information.
xii. Misuse of position and/or information.
xiii. Concealment of any of the above.

3. General Principles

i. All concerns or complaints will be treated fairly, impartially, and without prejudice.

ii. The identity of the whistleblower and the information provided will be kept strictly confidential, shared only on a need-to-know basis and with the explicit consent of the whistleblower.

iii. The Board of Directors is committed to protecting whistleblowers from any acts of harassment or victimization arising from their disclosure.

iv. No whistleblower will face any form of reprisal as a result of disclosing information in good faith, except in cases of malicious or knowingly false disclosures.

v. False and malicious allegations will be viewed seriously, and appropriate disciplinary actions may be taken.

vi. Whistleblowers are not protected from the reasonable consequences of their involvement in improper conduct.

4. Procedures

4.1 Reporting:
Whistleblowers should immediately, and in good faith, report any information on improper conduct to their immediate superior or management in writing. The report should include:

i. Full name and contact details.
ii. Background, date, history, and description of the misconduct.
iii. Identity of the suspected wrongdoer.
iv. Reasons for the concern.
v. Details of witnesses and all factual supporting evidence.
vi. Whether the whistleblower has any personal interest in the matter.
vii. Details of any actions already taken by others.
viii. Any other information that could facilitate an investigation.

If the immediate superior is unable to address the complaint, it should be escalated to higher management with the strictest confidentiality.

4.2 Investigation:
If the management deems the complaint worthy of investigation, it will be conducted independently and confidentially, with due consideration given to the available resources and in the shortest possible time.

4.3 Reporting to Audit and Risk Management Committee:
Whistleblowers may directly report to the Audit and Risk Management Committee if concerns persist or if the standard reporting channels are ineffective. The Committee may appoint independent officers, internal or external, at the expense of the Company, to investigate and report on the matter.

4.4 Other Considerations:

i. Cases involving criminal activity may be referred to the police at any stage of the investigation.
ii. Directors and employees are expected to fully cooperate with any
investigations initiated under this Policy.
iii. Directors and employees must refrain from any activities that victimize or harass whistleblowers making a complaint in good faith. Any such victimization, harassment, or reprisal will be reported immediately to the Audit and Risk Management Committee, and appropriate disciplinary action shall be taken.

5. Record Keeping

Upon completion of an investigation, all documentation pertaining to the complaint, including but not limited to the investigation report, corrective actions taken, and evidence, shall be maintained by the Human Resource Department.

For any enquiries regarding the matter please email our team at whistleblowing@koskinspecialist.com