Introduction
Concord New Energy Group Limited (the “Company”, together with its subsidiaries (the “Group”)) is committed to achieving the highest possible standards of openness, probity and accountability. Employees at all levels are expected to conduct themselves with integrity, impartiality and honesty. It is every employee’s responsibility and in all interest of the Company to ensure that any inappropriate behaviour or organisational malpractice that compromise the interest of the shareholders, investors, customers and wider public does not occur. To this end, the Company has devised this Policy.
Policy
The purpose of formulating the Policy is intended to assist individual employees to disclose internally and at a high level, information which the individual believes to show malpractice or misconducts within the Group. It is not designed to further any personal disputes, question financial or business decisions taken by the Company, nor should it be used to review any staff matters which have been addressed under the grievances procedure already in place.
Scope
The Policy applies to the Group’s employees at all levels and divisions/departments.
Misconduct and MalPRACTICE
It is impossible to give an exhaustive list of the activities that constitute misconduct or malpractice but, broadly speaking, the Company would expect you to report, amongst others, the following matters:
l criminal offence
l malpractice, misconduct or fraud relating to internal controls, accounting, auditing and financial matters
l improper conduct or unethical behaviour likely to prejudice the standing of the Company
l failure to comply with any legal obligations
While we do not expect you to have absolute proof of the misconduct or malpractice reported, the report should show the reasons for the concerns. If you make a report in good faith then, even if it is not confirmed by an investigation, your concerns would be valued and appreciated.
PROTECTION AND CONFIDENTIALITY
The Company will make every effort to keep your identity confidential and/or the identity of the individual employee making the report not being divulged without the employee’s consent. However, in certain circumstances, the Company may be required or legally obliged to reveal the employee’s identity to authorities without prior notice to you, for example, when an investigation leads to legal proceedings being initiated. In such case, the Company will take all reasonable steps to ensure that the employee suffers no detriment. Harassment or victimisation of a genuine whistle blower will be treated as gross misconduct, which may result in dismissal if proven.
FALSE REPORT
If you make a false report maliciously, with an ulterior motive, without reasonable grounds for the accuracy or reliability of the information in the report, or for personal gain, you will face disciplinary action. Harassment or victimisation of a genuine whistle blower will be treated as gross misconduct, which may result in dismissal if proven.
REPORTING AND INVESTIGATION PROCEDURES
Any report under the Policy must be submitted in writing to the company secretary of the Company at 3901/F., 39 Floor, Far East Finance Centre, 16 Harcourt Road, Admiralty, Hong Kong or CWP Bldg., No. 9 South Shouti Rd., Haidian District, Beijing in a sealed envelop clearly marked “Strictly Private and Confidential – To be Opened by Addressee Only” to ensure the confidentiality.
Employees are required to put their name to any disclosures they make. Anonymous complaints usually would not be considered.
A report should be made in writing, by using either the standard report form attached to the Policy as Annex I or in any other format suitable to the nature and particular circumstances of each complaint made, accompanied with sufficient supporting evidence.
We will evaluate every report received to decide whether a full investigation is necessary and the matters raised may be investigated internally by internal audit or compliance department (if appropriate) or referred to the external auditors of the Company, whichever is appropriate.
When possible, the chairman of the Board will acknowledge receipt and/or give feedback to the whistle blower.
REVIEW OF THE POLICY
The audit committee of the Company should review the effectiveness of the Policy regularly and ensure that proper arrangements are in place for the fair and independent investigation of such matters and for their appropriate follow-up action.
April 2022
ANNEX I
WHISTLEBLOWING REPORT FORM
CONFINDENIAL
We are committed to the highest possible standards of openness, probity and accountability. In line with that commitment we expect employees who have concerns about any suspected misconduct or malpractice within the Group to come forward and voice those concerns.
It is recognised that in most cases the person raising concerns will wish to be dealt with on a confidential basis. All reasonable efforts will therefore be made to avoid revealing the person’s identity.
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Your Name/Contact Telephone Number and Email |
Name:_________________________________ Address:_______________________________ ______________________________________ Tel No:________________________________ Email:_________________________________ Date:__________________________________ |
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The names of those involved (if known): |
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Details of concerns: Please provide full details of your concerns: names, dates and places and the reasons for the concerns (continue on separate sheet(s) if necessary) together with any supporting evidence. |
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CONFINDENIAL
April 2022