1. POLICY PURPOSE
   • HealthServe Ltd (“HSL”) do not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff in the course of their work. This Policy is intended to provide a framework to promote responsible and secure whistle blowing without fear of adverse consequences.
   • The Policy aims to create a work environment where Employees, vendors, service providers,
     beneficiaries and other stakeholders are able to raise concerns on misconduct, irregularities or
     malpractices, without fear of harassment and/or victimization and with an assurance that their
     concerns will be taken seriously and investigated, and the outcome duly communicated.
   • It is intended to encourage staff and other relevant stakeholders to report unethical or illegal conduct.
     Policy objectives include:
     • Encourage timely reporting of alleged malpractices/misconduct;
     • Provide a confidential channel for escalation of concerns without fear of reprisal;
     • Ensure consistent and timely response to reported improprieties and awareness by whistle blowers of their options/rights;
     • Ensure appropriate oversight by the Board of Directors;
     • Serve as a means of preventing and deterring misconduct that may be contemplated;
     • Protect the rights of HSL; and
     • Promote a culture of openness, accountability and integrity.
2. APPLICATION
   • This Policy applies to:
     • All Employees including but not limited to the following: full time staff, contract workers, interns, or any other person associated with HSL (collectively referred to as “Employees” in this Policy); and
   • The Policy allows for reporting by Employees to Chair of Audit Committee, without fear of reprisal, discrimination or adverse consequences, and also permits HSL to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.
   • Reportable incidents for whistle blowing include:
     • All forms of financial or non-financial malpractices or impropriety such as fraud, corruption, bribery or theft.
     • Harassment and abuse and misrepresentation of power and authority;
     • Failure to comply with laws and regulations;
     • Actions detrimental to health and safety or the environment;
     • Discrimination on the basis of gender, race, disabilities;
     • Serious conflict of interest without disclosure;
     • Breach of HSL’s policies and
     • Concealing information about any of the above malpractice or misconduct
   • Whilst the whistle blowing procedures allow anyone to report possible improprieties, it excludes employee grievances or disagreements which should be handled by the HSL Senior Management.
3. GUIDANCE
   

   Reporting Mechanisms

   • HSL encourages Employees to put their names to their allegations whenever possible. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the following:
     • Seriousness of issues raised;
     • Significance and credibility of concerns;
     • Likelihood of confirming the allegation from attributable sources and information provided.
   • All valid concerns or irregularities raised will be acknowledged and treated with confidence
     throughout the process.
   • Concerns may be raised verbally or in writing. As it is essential for HSL to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The Receiving Officer is the Chair of Audit Committee.
     Email: [email protected]

     
     Safeguards

   • HSL prohibits discrimination, retaliation or harassment of any kind against a whistle blower who submits a complaint or report in good faith. If a whistle blower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the Chief Executive Officer or Board Chair. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.
   • At the appropriate time, the party making the report/complaint may need to come forward as a witness. If an Employee makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. If, however, an Employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her.

     
     Complaints Handling

   • 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.
   • HSL reserves the right to refer any concerns or complaints to appropriate external regulatory
     authorities. Depending on the nature of the complaint, the subject of the complaint 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.
   • If, at the conclusion of an investigation, HSL determines that a violation has occurred or the
     allegations are substantiated, appropriate disciplinary action in accordance with the Fair Employment Policy will be taken. Non-anonymous whistle blowers will be informed that action has been taken at the conclusion of the investigation, without divulging confidential information.

     
     Handling External Media

   • In disclosing to external media with regards to alleged misconduct through the whistle blowing
     channels, HSL will ensure that there is fairness and objectivity in its corporate statements with no misrepresentation and unprofessional pursuit of publicity.
   • Where information is confidential, HSL shall not, except in the course of duty or under compulsion by law, disclose, divulge or make public any information of a confidential nature relating to the details of the alleged misconduct.
   • During the course of investigation, the whistle blower or any party privy to the confidential
     information shall not inform external media or any colleagues.
4. ADMINISTRATION – COMMUNICATIONS, TRAINING AND POLICY REVIEW
   
   Communications and Training
   
   • Principles and procedures of the Whistle Blowing Policy shall be communicated to all relevant
     stakeholders at the outset and as appropriate thereafter.
   • Employees should read, understand and comply with this policy. All Employees are responsible to ensure the highest standards of ethics, honesty, openness and accountability in line with the HSL’s
     commitment to enhance good governance, transparency and safeguard the integrity of HSL.
   • All relevant Employees shall be trained on the principles of this Policy periodically.

     
     Policy Review

   • The Whistle Blowing Policy shall be reviewed regularly, where the HSL may modify this Policy to
     maintain compliance with applicable laws and regulations or accommodate organisational changes. This review should be carried out by Chief Executive Officer / Senior Management.

Last updated: 1 April 2023