- INTRODUCTION :
The term 'whistleblowing' has been used to describe incidents where an employee or member of an organization publicly discloses some alleged wrongdoings within an orgaization. The main objective of having a whistleblowing policy is to create a climate of transparency in the organization in which employees can raise genuine concerns about possible malpractices without fear of reprisal.
The aim of the policy is to ensure that employees making allegations of malpractices in good faith can be confident that they will suffer no detriment for having raised their concerns and that any allegations of malpractice will be fairly investigated and proper action taken.
- SCOPE OF THE WHISTLE-BLOWING POLICY
As a guide, the scope of disclosure for the whistleblowing policy would include:
2.1 Accounting Practice Reporting
* Fraud or deliberate error in recording and maintenance of financial records or in preparing, evaluation or review of any financial statements of the Group;
* Deficiencies in or non-compliance with the Group's internal controls and procedures;
* Any misrepresentation by an officer or auditors regarding a matter contained or required to be contained in the Group's financial records, reports or audit reports; and
* Forgery or alteration of a cheque, bank draft, or any other financial document.
2.2 Non-Accounting Practice Reporting
* Misappropriation of funds or other assets;
* Misuse of Petty Cash;
* Falsifying Attendance Record;
* Pilferage of Stock in Trade;
* Fraud or suspected fraud, theft and dishonest acts;
* Profiteering as a result of insider knowledge of company activities;
* Accepting or seeking anything of material value from vendors, suppliers etc;
* Sabotage of the Group's IT systems;
* Improper conduct or unethical behaviour;
- SAFEGUARDS
3.1 Protection of Employee - Confidentiallity
The Company will treat all information received confidentially and the identity of the person disclosing the information will be protected. As such, it is preferable that the individual indicates his/her name to any disclosure although anonymous disclosure will be accepted.
3.2 Anonymous Allegations
The policy requires employee to puit their name to allegations because appropriate follow-up questions and investigations may not be possible unless the source of the information is identified. Concerns expressed anonymously will be investigated, but consideration will be given to :
- The seriousness of the issue raised;
- The credibility of the concern; and
- The likelihood of confirming the allegation from attributable sources.
3.3 False or Malicious Disclosure
False or malicious allegations which lack any objective basis will not be tolerated, as this will cause unnesessary waste of time for management and anxiety for the person being investigated. Appropriate disciplinary action will be taken against employees who abuse the whisteblowing mechanism.
3.4 Non-Retaliation
No adverse action wil be taken against any employee or other individual for making a complaint or disclosing information in good faith under this Policy. - PROCEDURE AND PROCESS
4.1 Reporting
* Reporting can be made in person or phone call (via designated phone numbers) or in writing (via email/post);
* Although the employee is not expected to prove the truth of an allegation, the employee needs to demonstrate to the person contacted that there are sufficient grounds for concern;
* All reports made in good faith will be properly heard and dealt with;
4.2 Reporting Channels
Address : C/o Company Secretary or Transit-Mixed Concrete Ltd
150 Changi Road #03-05 Guthrie Building Singapore 41997
Attention: Chairman of the Audit Committee of the Company
Email: kheagled@gmail.com or llchen@tmcltd.com.sg
The whistleblowers can still report directly to the relevant officer-in Charge whom he/she feels more comfortable with.
4.3 Handling of a Complaint
The action taken wiil depend on the nature of the concern, initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved by agreed action without the need for investigation
If investigation is necessary,the Audit Committee of the Company will direct an independent investigation to be conducted on the complaint, The Board of Directors receives a report on that complaint, findings of investigation and a follow-up report on actions taken.
4.4 Report to the complainant
The complainant will be given the opportunity to receive follow-up on their concern in two weeks;
- Acknowledging that the concern was received;
- Indication how the matter will be dealt with;
- Giving an estimate of the time that it will take for a final response.
- REPORTING OF OUTCOMES
5.1 Subject of legal constraints, the complainant will receive information about the outcome of any investigations.
5.2 An official written record will be kept of eachstep of the above procedures. All such documentation shall be retained by the Company for a period of five (5) years from the date of receipt of the complainant. Thereafter, the Audit Committee will bave the discretion to authorize the records to be disposed of. Confidentiality will be maintained to the fullest extent practicable depending on the requirements of the investigation.
signed
DAVID LIU
ACTING CEO
About Whistle-Blowing Policy & Procedures
Transit-Mixed Concrete Ltd (hereinafter referred to as "Company"), its subsidiaries and associates (collectively defined as "Group") requires its directors, managers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. The Company is committed to the highest possible standards of ethical, moral and legal business conduct. In line with this commitment and the Company's commitment to open communication, this policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith.
About TMC Concrete Pumping Services Pte Ltd
TMC Concrete Pumping Services Pte Ltd (TMCCPPL) are the leading concrete pump rental supplier in Singapore with total of more than 70 units of truck mounted concrete pumps, trailer pumps and concrete placing boom equipments.
We supply truck mounted pumps to major projects like Kallang/Paya Lebar Expressway, Marina/Sentosa Intergrated Resort, Marina Bay Business Finance Centre, etc in Singapore. Our Trailer Pumps have so far achieved the longest horizontal distance of 1.5 km in Singapore.
Our Trailer Pumps & Concrete Placing Booms are also involved in projects in Malaysia and Indonesia.
About TMC Waste Management Pte Ltd
TMC Waste Management Pte Ltd (thereinafter known as TMCW) is registered on 17-09-2002 to perform liquid waste disposal services and cleaning of sewer pipes and grease-interceptors. TMCW is wholly owned by Transit-Mixed Concrete Ltd, a public-listed company in the construction industry which has wide business contact with the local construction companies and work sites.
With the advantage of this network, TMCW started to disposed sewage for these construction sites with its first vacuum-tank in November 2002. At the same time, TMCW attained its class “C” licence from (NEA National Environment Agency) for the disposal of liquid kitchen-waste, often known as greasy waste.
In 2003, greasy waste from restaurants, hotels and other eateries increasingly become the main source of business for TMCW as demand of sewage disposal decreased with the shrinking construction industry.
To date, TMCW acquires 7 vacuum-trucks with another 3 high-pressure water jetting truck-mounted machines to complement its greasy waste disposal business, including services in the cleaning of pipes and clearing of pipe blockages / chokes.
TMCW has its newer trucks approved by NEA and Certified fit for performing toxic-waste disposal by professional engineers. Services contracted include the cleaning of oil-interceptors, disposal of waste oil and cleaning of sewer pipes in the kiosks and oil blending plants.
TMCW has acquired 5 sewer video cameras for the CCTV inspection of sewers for diameters varying from Ø 50mm to Ø 3000mm.