ST Telemedia is committed to principles of lawful and ethical business conduct. To this end, all employees are encouraged to seek guidance, raise concerns and/or report violations of ethics and compliance matters using the resources provided by ST Telemedia, including under the ST Telemedia Whistle Blowing Policy (“WBP”).
As part of ST Telemedia’s commitment to conduct its business with integrity, employees are encouraged to speak up about their genuine concerns in relation to, among others, any actual or suspected criminal activity, bribery, breach of a legal obligation (including negligence, breach of contract, breach of security, breach of administrative law), miscarriage of justice, danger to health and safety of employees or general public, damage to the environment, and the cover up of any of these issues in the workplace. Employees who have raised concerns or violations in good faith and reasonably believing them to be true, will be protected from retaliation. Further, a whistle blower who has no personal interest in the subject matter of the whistle blowing report would not be expected to prove the case, and his or her duty is simply to raise the concern so that the same can addressed in accordance with the WBP. In rare situation where the whistle blower has a personal interest in the outcome of any investigation to his or her whistle blowing report, he or she may be called upon to prove his or her case.
All reported concerns will be addressed and the investigation will be dealt with in confidence.
An independent (outsourced) service provider has been appointed for employees to raise ethics and compliance related questions or to report a concern or a violation in accordance with the WBP. Where permitted by law, whistle blowing reports may be made anonymously. However, anonymous feedback may not be accorded the same level of attention.
Further, employees who wish to raise any concerns or violations, or feel that they have suffered retaliation from raising such concerns, are encouraged to contact the head of Human Resources or Legal department of ST Telemedia, or a member of the Ethics Committee or Audit Committee.
The Ethics Committee is responsible for addressing questions, concerns and violations raised pursuant to the WBP, providing oversight to any investigations arising thereto and implementing measures of rectification and prevention, where required. All concerns or violations raised will be reported to and reviewed by the Audit Committee. If the subject matter of the whistle blowing report involves a member of the Audit Committee or the Ethics Committee or a member of the department of any Ethics Committee member, such Audit Committee or Ethics Committee member, as the case may be, shall recuse himself or herself from overseeing the investigation of such concerns or violations and the remaining members of the Audit Committee or Ethics Committee, as the case may be, shall have oversight over such subject matter.