WHISTLEBLOWING POLICY

flexi2pay is committed at conducting our business with the highest standards of honesty, integrity and transparency. We expect our employees and partners to maintain the same standards of value.

This policy offers guidelines about how to raise questions about wrongdoing within flexi2pay organizations, our affiliate organizations or any other organizations with which we are affiliated.

It aims to ensure that you can do so with trust and without having to worry about being abused, discriminated against or compromised in any way, should you wish to raise any serious concerns.

  1. What types of concern it covers

    This policy is intended to deal with serious or sensitive concerns about wrongdoing, within the SEA region or in the countries where flexi2pay operates, including the following:

  2. Types of Wrongdoings

    A whistleblower can report a complaint if he/she is aware of any wrongdoings, including, but not limited to the following:

    • Criminal offences like bribery, fraud;
    • Intentional misrepresentations, misstatements, omissions, directly or indirectly affecting financial statements; or
    • Failure to comply with any legal obligations;
    • Danger to the health and safety of any individual or the environment;
    • Improper conduct or unethical behavior; or
    • Attempts to conceal any of the above.
  3. Acting in Good Faith

    To ensure credibility and avoid disclosures which are malicious, frivolous and/or vexatious, the whistleblower is required to put his/her identity to any disclosures made and shall ensure that the disclosure is based on facts and evidence.

  4. What types of concern it does not cover?

    This Policy provides an alternative avenue for Persons to raise concerns if the normal lines of communication are not available. Nothing in this Policy shall interfere with other established operational policies and processes of flexi2pay.

  5. How to raise a concern

    Any person who is aware of suspicions, allegations or actual wrongdoing by a person involved with flexi2pay’s work, either within the SEA region or in the countries where we operate, has an obligation to notify the Whistleblowing Officer immediately

  6. Whistleblowing Channel

    Any complaints or disclosures can be made by sending an email to support@flexi2pay.com

  7. How we respond to concerns

    The way we deal with a concern will depend on what it involves. We will first make enquiries to decide whether we should carry out an investigation and, if so, how we should go about it. Your concern may be investigated thoroughly and dealt with the disciplinary process, or we may refer it to the following:

    • the police
    • our external auditor
    • an independent investigator

    If your concern or allegation can be handled under any other procedure or policy, we will pass it on to the relevant person and inform you. If we need to take urgent action, we will do this before carrying out any investigation.

    The amount of contact you have with our appointed officer will depend on the nature of your problem, the possible problems involved, and how straightforward the details provided.

    If you need to have a meeting to address the issue, you may be accompanied by a trusted friend, colleague or manager who recognizes the need for full confidentiality clearly. Meetings would usually take place in appointed officer but also may be held elsewhere, if desired.

    As long as this does not infringe any obligation of confidence, the whistleblower should be given as much input as is necessary during the process and in respect of the result.

    It is also necessary to note that a whistleblower is a witness, not a plaintiff. The whistleblower’s job is to let the facts speak for themselves and allow the responsible Whistleblowing Officer to decide what action should be taken. We would expect workers to raise issues earlier rather than waiting for proof, considering the consequences of not blowing the whistle too is important.

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