Social Responsibilit'λ&y
I.Purpose
This whistleblowing policy is±∞ designed to encourage employeπλ♠♣es of the Company (together with€×ε→ its subsidiaries, the “Grou☆↔p”), and related third p>Ωarties (e.g. custome"♦πrs, suppliers, etc., who deal'≥λ with the Company) (“Third Part'σσies”) to raise concer™δ↔•ns, in confidence, about misconduct, m≠§δalpractice or irregularities inσ& any matters related to the Co✘×β♣mpany.
II.Responsibility to Re★port
To set forth our specΩ±©¶ific obligations, the Company has ≠£an Employee Handbook (“Employee H↔∏andbook”). The Employee Handbook proα&↑vides the guiding principles for a£♦₽♠ll employees to take the ri♥♣∑ght action, behave with integ♦β± rity and honesty, treat peop≠le fairly, respect diβ™♦λversity, obey all laws, accept acco®↓untability, communicate openl→ y, and always behave in☆×≠β a way that is beyond reproach.
Under the Employee Handbook, employ★✘ees are required to promptly alert ♠§their supervisor or higher manag₹≥ement of business and work-✘↑Ωrelated situations that coul← d be damaging to the Company or cause©$ harm to others such as e≥γ$♥mergencies, crimes, accidents, irreg≈$δσularities or other unexp↔φected events; and to take reasonable ac∞©↓tion to prevent damage or"' harm. Employees cou®∞ld be in breach of the Employee Handboσ∏÷€ok if they assist or authori$®∞ze others in activities that breach€§σ← the Employee Handbook, ε £conceal or fail to report any known↓< or suspected breaches by others.♥≤ Employees and Third Parties may₩☆♦↔ also have a duty to report corrup₽∏ tion to the authorities if r✘₽ equired to do so by loc÷πal regulations.
III.Protection
Persons making genuine and'φ☆ appropriate complaints unde•γr this policy are ass>™ured of fair treatment. In addition, t σ☆≠he Group’s employees a↓•re also assured of protectio→♥'±n against unfair dismissal, victimi↔zation or unwarranted disciplinaφ¶δry action, even if the coΩ®ncerns raised turned out tε≈$o be unsubstantiated. The Group reserv∞$αes the right to take¥λ₹ appropriate actions ag®®$$ainst anyone (employees or Third Partieσ's) who initiates or threate••✘ns to initiate retalia'♦♠♦tion against those who™♦ Ω have raised concerns under this policy♥≈. In particular, empl∏÷™®oyees who initiate or threaten€§♠ retaliation will be subε£™ject to disciplinary actions under tΩλ±he Employee Handbook, w×♥$®hich may include summa≥$∑ry dismissal. Management w←βδ&ill support all employee↔πs and encourage them ±∑ Ωto raise concerns without fear of ₽®reprisals.
IV.Confidentiality
The Group will make every ε↕™effort, within its capac γ₩✘ity to do so, to keep a Whistlebl✘εower’s identity confidential✔→. The Group will end↑®eavor to advise a Whistleblower in ₽'advance if his or her ide™ ntity may become apparent ∞¶or need to be disclosed. Should an inv✔&estigation lead to a criminal p"↓<rosecution, it may become necessary¥© for a Whistleblower to p∞≈rovide evidence or be inα€terviewed by the relβ¶×πevant authorities.
V.Types of Misconduct, Ma$•€←lpractice and Irregularity
It is not possible t←±↔∑o give an exhaustive list of ©γ¶ the activities that c∑αonstitute misconduct, Ωφ☆₹malpractice or irregula™↑∏₹rity covered by this polic™&≠y. For example, the Group expects al∞✘l employees to observe and apply th™✔e Employee Handbook principl₽αes in the conduct of the ♥•≠Group’s business. Employee behavior↑φγ that is not in line with ♦'Employee Handbook principles♥β↔ could constitute a misσ₹conduct, malpractice, or irre♥↔♣∞gularity that should be repo♠$↔£rted. The principles of E≥γ ₽mployee Handbook relate to:
VI.Reporting and Investigations
a）Reporting Channels
In general, Whistleblowers shou♥ ld make their reports to the ε♠Human Resources Department ×Ω&€under the Group’s Executive Oλ©∞ffice (“Group HR”) for review.€£₩
For employees, they may preferλ•→" to have an initial discuss∑ ≥ion with his/her manager or lΩ>>ocal HR representatives. Howα<ever, the manager or HR must in turn ☆↕®εreport any potential£ or actual misconducts, malpractφ∏ices or irregularities to Group H←$R. If employees feel unco'σmfortable doing this (e.g. his/her ♣♠line manager has dec©↓↑lined to handle his/her ca↕♠©se or it is the line >§&€manager who is the subject of t→φhe report), then the emεσ↕ployee should contact Group λ≤©✘HR. Business partners,©•✔™ suppliers and Third Parties are encour≤>&aged to report directly to Group ≥÷HR.
b）Reports and Supporting♣ Documentation
While the Group does not exε→pect the Whistleblower to have abs♣ olute proof or evidence of the mi¶φ ♣sconducts, malpracti♣§ ↑ces or irregularities reported, theλ¶ report should show the reasons fo §r the concerns and full disc∑✔₽γlosure of any relevant details and∑™ supporting documentation. If he/she€Ωφ make a report in good faith then, e∏×ven if it is not confirmed★δ by any subsequent investigatio€←✘n, the Whistleblower’s γ© <concerns would be valued and appε €→reciated. He/she can make a£↑ report as follows: in writi≈€ng (by email to ethics@silvergrant.coαεσm.cn or by post) to Groσα÷up HR using the standard fo↔♥φ rm (Whistleblower Report ✔ Form) attached as Annex®α✔ 1 of this policy.
Manager/HR representative i&σs required to summit♥ to the Group HR a lλαog summary of all rec♠✔β<eived/recorded reporting forms•↑ and corresponding act¥¥ions taken on a regular basis.
Group HR will implemen★±t safety custody procedure÷∞≠s to save guard all reporting for∞♣ms to protect confidentiality o±•f all email address and¶σ¶ phone numbers.
c） Investigations
Group HR will assess every repo₹∏rt received through th ♠$§e general reporting channel describ¥₹ed in section VI (a) above to dec₩₩ide if a full investi♥® gation is necessary.↔σ If there is sufficient≈™> evidence to suggest that a cas©♣€e of possible criminal offence or←♥ corruption exists, the matter will γ'π≠be reported by Group HR to±®✔ the relevant local authoriti€₽÷•es (for instance, Inπφdependent Commission Against Corε↑ruption (“ICAC”) in Hong Kon±"g).
In some situations (e.g. in ™₩ case of possible criminal of<α±fence), Group HR may have to refer<εα the matter together with t∞Ω≈™he relevant information to t♦ he authorities. Please note t¶'hat once the matter is£γσ referred to the authorities, ≈™♥the Group will not be able to take fu¥δrther action on the m←≈'£atter. 。
Group HR will prepare a full ✔$♣report on the investigations conducted &♣without revealing the identity of the€₹≤ Whistleblower. For confi ♠✔↑rmed cases of Employee Handbook£λ↓' violations, the nor♥ πmal process is for t׶Ωhe responsible line management₹©™ (with the assistancβ±e of HR representative) to determ≥✔ine what disciplinary actionσ is appropriate and make≤$✘ a recommendation to the Gr♦>'oup HR for final decision.
VII.False Reports
If a Whistleblower makes a false repor××↑t maliciously, with an ulterior≤∑₹' motive, or for perso₹∏nal gain, the Group reserv££✔es the right to take appropriate act♣€ions.
VIII.Anonymous Reports
As the Group takes reporting γ<∞ of misconducts, malpraε®Ω'ctices, and irregulariti₩$γφes seriously and wants to co'≤πnduct warranted inves↕ααtigations of both potential and actu₩®÷₩al violations, it is λ∞preferred that these reports are not☆≠←÷ made anonymously. However, i®≈≠t is recognized that for any n™✘≥umber of reasons, emplo☆↓≈✔yees or Third Parties may not ✘♦βfeel comfortable reporting potentiΩπ£al violations directly to Grou&∞p HR. In these cases, anonymou★€→s reports may be submit €ted to the Group HR.
IX.Record Retention
Records shall be kept fo '®™r all reported miscon₹≠∏→ducts, malpractices, and irregulariεα®ties by the relevant parties in the Gro®€up under Section VI '←>(a) above. In the event a reported irregularity leading t×≤↔o an investigation, the party re ₩§"sponsible for leading /< conducting the investigation s₹≈©hall ensure that all relev¶✘ant information relating to the case i♦≤'αs retained, including details of & corrective action t ®aken for a period of six years (o✔∏'"r whatever other period≤π<§ may be specified by any relevant legisπ™lation).
X.Responsibility for Implemen↑εtation and Review of Policy
This policy has been approved and $±₽®adopted by the Board of the Company. The Audit Committee has been del↑≤egated overall responsib"©γ☆ility for implementatio≈♠n, monitoring and periodic review ™εof this policy and any matter ∑€raised must be put forward to the ™Board for approval. In addition, > ≈the Audit Committee has delega±α₹ted the day-to-day responsibility for₽ ✘ administration of the policy to the ≥ ₹↕Group HR. If there are any questions↔ γ about the contents or☆®÷ application of this policy,↕β↓ please contact Group HR.
