Whistle Blowing

At Constellar, we are committed to upholding high standards of business and personal ethics, honesty, and integrity. Our directors, management and employees are expected to fulfil their responsibilities within all applicable laws and regulations.

Our Whistle Blowing policy provides a safe and confidential channel for directors, employees and external parties to report any impropriety committed by Constellar staff in a responsible and effective manner.

Reportable Concerns

A whistle blower may report any action or omission within the company relating to unlawful conduct, financial malpractice, violation of law, rule, regulation or policy, or a direct threat to the interest of the company.

Examples of reportable improprieties include:

1. Staff Fraud

Cheating, corruption, bribery, misappropriation of funds, collusion with 3rd parties, fraudulent financial reporting, etc.

2. External Fraud

Fraud, corruption by external parties, service providers, suppliers or agents against the company, etc.

3. Staff Conduct

Breach of staff regulations, conflict of interest, misconduct, dishonest claims, theft, sabotage of work processes, misuse of information, abuse of power, unfair treatment, discrimination, harassment, etc.

4. Business Conduct

Anti-competitive practices, violation of regulations, discriminatory treatment, financial reporting non-compliances, mistreatment of confidential information, etc.

Confidentiality 

Whistle blowers are encouraged to identify themselves when raising concerns or providing information. All information provided will be treated with the strictest confidentiality.

Constellar will not tolerate victimisation of the whistle blower, and appropriate disciplinary action will be taken against those who do so. If the whistle blower is an employee of Constellar, their employment will be protected even if the report is proven to be unfounded, provided that the report has been made in good faith.

Reporting Channels

Whistle blowers can raise their concerns in writing via letter or email.

Whistle blower reports should detail the background, history of events and the reasons for raising concern.

Any concern raised or information provided via the whistle blowing channels listed above will be brought to the attention of the Chairman of the Audit Committee or the Chairman of the Board and investigated. Consideration will be given according to its seriousness, credibility and likelihood of confirming with attributable sources.

The whistle blower will be kept informed of the progress of the investigation and where appropriate, the final outcome, subject to any legal or confidentiality constraint.