1. Introduction

Whistleblowing is an act of reporting any kind of information or activity in an organization that is deemed fraudulent, illegal, and unethical. It is an important aspect of fraud risk management. The development of a policy to guide whistleblowing is in line with the commitment of the management of Avon Health Care Limited (the “Company”) to drive the highest possible standards of transparency, probity, and accountability and encourage the adoption of leading practices in fraud risk management.

 

2. Purpose

The purpose of this policy is to provide a mechanism for reporting and investigating suspected cases of fraudulent and illegal activities, to encourage all stakeholders to report suspected cases of fraudulent and illegal activities and to reinforce the Company’s non-victimization policy for any stakeholder that reports concerns in good faith.

 

3. Scope

The Whistle-Blowing Policy applies to the reporting and investigation of fraudulent, unethical, and illegal activities as well as safeguards available to whistleblowers. It does not apply to or change the Company’s policies and procedures for individual employee grievances and complaints relating to job performance as well as terms and conditions of employment. These would be handled through the Human Resources Department in line with the provisions of the Human Resources Policies as well as other applicable policies and procedures.

 

4. Responsibilities

The Head, of Internal Audit, Risk & Control shall have primary responsibility for the implementation of this policy.

 

5. Definitions

• For this policy, the following definitions shall apply:

• Whistleblowing: this involves reporting events of misconduct, and illegal and unethical activities relating to or affecting the Company.
• Whistleblower blower: any person that makes a protected disclosure about illegal or fraudulent activities or improper conduct.
• Safeguards: arrangements made by the Company to protect a whistleblower.
• Good faith: the act of a whistleblower sending his/her report without malice or consideration of personal benefit and believing the report to be true to the best of his/her knowledge.
  
  

6.  Applicability

• This policy applies to all the Company’s stakeholders including:

• Vendors and other service
• Business partners and
• Job
• Official
  
  

7. Reportable Activities

• The following activities shall be reported through the Company’s whistleblowing mechanism:

• Illegal
• Fraudulent activities and financial irregularities
• Conflict of interest and abuse of
• Unethical
• Insider dealing and illegal information brokerage
• Misuse of physical and information
• Sexual
• Non-compliance with the provisions of the Group’s corporate values and principles.

• Activities that constitute a danger to life and
• All forms of bribery and
• Living above one

• Substance abuse / influence
• Suppressed past criminal
• Indecent exposures.
  
  

  8. Obligations of the Whistle Blower

• The whistleblower shall take note of the following obligations:

• All whistleblowing reports should be made in good
• The whistleblower should have reasonable ground to believe that the whistleblowing report is true; and
• The whistleblower should ensure that the report is not made to make some personal gains.

   

9.  Allegations in Bad Faith

Allegations that are confirmed to be made in bad faith shall result in disciplinary actions.

 

10. Safeguards

• Harassment or victimization: The Company will not tolerate harassment or victimization for reporting concerns under this policy and shall take all necessary steps to protect any stakeholder that reports a concern in good faith.

• Confidentiality: The Company shall treat all reports and reporters with the highest regard for

• Anonymity: Whistleblowing reports can be treated However, the Company encourages whistleblowers to put their names on the reports so that appropriate follow-up questions and investigations can be handled properly.
  
  

11. How to Raise Concerns

• As a first step, staff members are encouraged to raise concerns with their line managers or This depends, however, on the seriousness and sensitivity of the issues involved and whether the line manager or superior is thought to be involved.

• Concerns of a more serious and sensitive nature shall be raised in writing and sent in a sealed envelope addressed to the Head, Internal Audit, Risk & Control, or through the dedicated e-mail address [[email protected]].

• Concerns can also be relayed through a dedicated whistleblowing telephone number with the capacity for voice calls and text messages. You can call directly on [08125697479] (from abroad [+2348125697479]) at any time to speak with the Head, Internal Audit, Risk & The call will be treated strictly in confidence.
• Concerns considered highly sensitive by the whistleblower as well as concerns relating to the Head, Internal Audit, Risk & Control shall be sent to the Company’s Chairman.

• It is a serious disciplinary offense for any person to seek to prevent communication of concerns from getting to the Head, Internal Audit, Risk & Control, or the Chairman or to hinder any investigation arising from a whistle-blowing

• Although whistleblowers are not expected to prove the truth of an allegation, they will need to demonstrate to the Head, Internal Audit & Control, that there are sufficient grounds for their

• All stakeholders are encouraged to note that ‘the earlier a concern is raised, the easier it is to take action.
  
  

12.  Investigation of Reports

• All whistleblowing reports shall be thoroughly

• Whenever necessary, whistleblowers who indicated their names may be called upon to provide the necessary evidence to support concerns raised in the

• The Head, Internal Audit, Risk & Control, shall escalate the allegation to the Group Chief Executive Officer or the Chairman, depending on its

• The outcome of the investigation shall be communicated to the whistleblower (where the whistleblower indicated his/her name).

• The Company shall take disciplinary measures against offenders for all confirmed events.

• The Head, Internal Audit, Risk & Control, shall provide regular reports to the Governance Committee on whistleblowing reports received in the Company and the status of the investigation

13. Reward Scheme for Whistle-Blowers

A reward scheme has been designed for whistleblowers whose identities are known. Due to confidentiality issues, the names of identified whistleblowers will be restricted to key officers in the HR, Finance, and Internal Audit, Risk & Control Departments.

Where the information provided by the whistleblower is substantiated and confirmed true, and the concern raised will save the company from financial and/or reputational loss, a discretional reward in cash or kind, may be recommended and awarded to the whistleblower. The award process should be handled carefully to protect the identity of the whistleblower and preserve the integrity of the Whistleblowing Policy.

Whistleblowing Channels: How to Report?
To ensure confidentiality and ease of reporting, we provide multiple whistleblowing channels:
Anonymous Hotline 📞 – Call [08125697479] i. e available 24/7 .
SMS – Send text messages to 08125697479
Email Reporting – Send concerns to [email protected]