The Whistleblower Procedures establish a procedure for all employees of IFS Capital (Thailand) PCL (the “Company”) and stakeholders alike to submit complaints or concerns (a “Complaint”) relating to any potential unethical or unlawful behavior, financial improprieties or to report perceived violations of law or the Company’s policy.
The aim of these procedures is to ensure that all employees and stakeholders alike are confident that they can raise any matters causing them concern, with the knowledge that it would be taken seriously, be dealt with in the strictest confidence, and be acted upon without any fear of possible reprisals. Employees and stakeholders alike are therefore encouraged to submit their Complaints.
These procedures apply to all employees of the Company including Directors, Exucutives permanent, contract and temporary employees and stakeholders alike (“Complainant (s)”).
The Company will take all reasonable steps to safeguard the identity of the whistleblower.
All Complaints shall be treated as confidential. All investigations will be conducted in a confidential manner, so that information will be disclosed only as needed to facilitate the investigation or otherwise as required by law.
Any whistleblower who makes a Complaint in good faith should not have fear of reprisals.
The details of how a Complaint can be made and how it will be handled are set forth below.
(A) Submission of a Complaint
- Complainants are free to submit their Complaints confidentially in writing or in person, through letters, e-mails or telephone calls; or anonymously by internal or regular mail.
- Complainants are free to submit their Complaints to any of the following persons:
- If the Complaint concerns any of the above persons, Complainants may make their Complaint to the Audit Committee via a letter sent to the following person and address:
Chairman of the Audit Committee
IFS Capital (Thailand) Public Company Limited1168/55, 20th Floor, Lumpini Tower, Rama 4 Road,
Tungmahamek, Sathorn, Bangkok 10120
If the Complaint concerns financial improprieties (such as questionable accounting, internal accounting controls or auditing matters), employees may make their Complaint directly to the Chairman of the Audit Committee.
(B) Action To be Taken
Before the person who receives the Complaint decides to proceed with the matter under this Whistleblower Procedures, he would reconfirm with the Complainant that his identity is not to be disclosed.
Upon confirmation of the Complainant, the person who received the Complaint shall take down the statement from the Complainant. To safeguard the confidentiality of the identity of the Complainant, the statement shall remain in the custody of the person who received the Complaint.
In the event where an anonymous Complaint is received, the investigation of the Complaint will be carried out based on the information or documentation provided by the Complainant. In cases where there is insufficient information or documentation provided, it may not be possible to proceed with or properly conduct an investigation.
The person who received the Complaint must notify Head of IR, Secretariat & Compliance Department immediately that a Complaint has been made to enable the Compliance to maintain a log of all Complaints made under this procedure. The person who received the Complaint must also notify the Head of Human Resources & Admin Department or Company Secretary that a Complaint has been made, unless the Complaint concerns the Human Resources & Admin Department or Company Secretary.
The person who received the Complaint, in consultation with the Chief Executive Officer (however, if the Complaint involves financial improprieties of the Chief Executive Officer, then Chairman of Audit Committee should be consulted instead of the Chief Executive Officer), would:
- Review and submit the Complaint to the Investigation Committee
- Oversee the progress of the conduct of the investigation by the Investigation Committee
- Determine a plan of action
- Summarize and report the investigation results
Once the investigation and evaluation of the Complaint has been completed, the Review Team (the person who received the Complaint and the Investigation Committee) shall report to the Chief Executive Officer or Chairman of the Audit Committee (in cases where the Complaint relates to financial improprieties of the Chief Executive Officer or where Complaint is made directly to the Audit Committee) on the results of its findings, the recommended plan of action and (where appropriate) the recommended disciplinary or remedial action, if any.
The action determined by the Chief Executive Officer or the Chairman of the Audit Committee to be appropriate under the circumstance shall, where deems necessary by the Chief Executive Officer or the Chairman of the Audit Committee, be brought to the Board for authorization or implementation.
The Complainant who made the report will be kept informed of the final outcome of the matter.
Reasonable and necessary steps will also be taken to improve the processes (if necessary) to prevent any improper conduct from occurring in future or to prevent any further violations of the Company’s policy.
The Board of Directors, management and employees must understand and follow this Whistleblower Policy in order to achieve the Company’s goals and objectives which effective since 7th May 2019 onwards.