Whistle Blowing

Version 2.0

Policy Title
Effective Date

Whistle Blowing
1 November 2013

Policy Statement
Employees are expected to adhere to the employee code of conduct and demonstrate the
highest professional standards in executing their job responsibilities.
The Company encourages anyone to bring any ethical and legal violations that they are aware
of to the Managements attention so that appropriate action can be taken immediately to
address the problem, and to minimize the Companys exposure to any damage that may occur
when employees circumvent or overstep internal processes.

1.1 Objective
The policy reaffirms the Companys commitment to good corporate governance. It also serves
as a guide for employees and anyone outside of the Company to raise any concerns in a
responsible manner. The policys intent is to create an environment where employees
understand their responsibilities and Management can demonstrate their accountability.

1.2 Scope
The policy applies to all employees in the Company.

1.3 Responsibility
All employees are responsible for ensuring compliance to this policy.

Whistle Blowing
a.

A whistle blower is someone who witnesses behaviour by an employee that is either

contrary to the mission and core values of the Company, or threatening to the public
interest, and who decides to highlight the issue to the relevant internal authorities for
purpose of scrutiny and rectification.

b.

This policy will enable the Management to take the necessary corrective action when
something is found to be amiss. It is not a means where a disgruntled individual can
abuse and seek to wreak revenge by giving away trade secrets or hold an employee to
ransom.

c.

Areas For Whistle Blowing

i.

following are possible scenarios where whistle blowing may be raised. This
may be based on information, which the whistle blower reasonably believes
and/or establishes that, inappropriate behaviour has happened in the past, is
currently happening or is likely to happen in the future:

StarHub Ltd.

a criminal act;
the breach of a legal requirement;
inappropriate behaviour such as bribery;
a miscarriage of justice;
a danger to the health or safety of any individual;
damage to the environment; or
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deliberate cover-up of information which supports any of the above

matters.

Difference between Blowing the Whistle and Making a

Complaint
a.

In practice, whistle blowing occurs when an individual raises a concern about danger
or a legal requirement that affects others (e.g. customers, members of the public, or
the Company). The person blowing the whistle is usually not directly or personally
affected by the danger or illegality, and hence does not have a personal interest in
the outcome of any investigation into the raised concerns. As a result, the whistle
blower who has no personal interest would not be expected to prove the case, and
his or her duty is simply to raise the concern so that others can address it. In rare
situation where the whistle blower has a personal interest in the outcome of any
investigation, then he or she may be called upon to prove their case.

b.

On the other hand, in a complaint, one is asserting that there is/are person(s) who
have been poorly treated, for instance. The treatment could involve a breach of the
individuals employment rights or a case of bullying, intimidation or harassment. The
complainant is seeking redress or justice for hurt done. The complainant therefore
has a vested interest in the outcome of the complaint and, for this reason, is expected
to be able to prove their case. For cases on grievances, please refer to the Policy on
Grievance Procedures.

Procedures
a.

When an employee has witnessed an incident of inappropriate conduct, he or she

should raise the matter to his or her immediate supervisor promptly and within
reasonable time. If he or she feels that this is not an appropriate person, he or she
should directly inform or write to the respective HODs or the Senior Vice President of
Human Resource. Meanwhile, he or she should be mindful of the following:

Think about the risks and outcomes before you act

Remember you are a witness, not a complainant
Think about what the end result may be before you take any action
Do not become a private investigator, especially where confidential information
is involved
Do not forget there may be an innocent and/or good explanation
Do not use this procedure to pursue a personal grievance

b.

Employees can be assured that those who have raised any concerns in good faith and
reasonably believing them to be true, will be protected from possible reprisals or
victimisation. As part of preserving integrity and protecting company assets, every
employee is encouraged to speak up about genuine concerns in relation to criminal
activity, bribery, breach of a legal obligation (including negligence, breach of contract,
breach of security, breach of administrative law), miscarriage of justice, danger to
health and safety or the environment, and the cover up of any of these in the workplace.
It applies whether or not the information is confidential. The Company views
victimisation of whistle blowers as a serious matter and will not hesitate to take
disciplinary action.

c.

When an individual who is not an employee has witnessed an incident of inappropriate

conduct, he or she should directly inform or write to the Senior Vice President, Human
Resource.

StarHub Ltd.

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d.

All reported incidents will be promptly and thoroughly investigated by the Company and
the investigation will be dealt with in confidence, with only relevant staff who need to
know, being informed.

e.

In this regard, the Company has set up an Investigation Committee (consisting of

members from Senior Management, Fraud, HR, Legal and/or such other relevant
departments depending on nature of the matter raised), to address and handle matters
arising from whistle blowing, as well as to implement follow through measures of
rectification and prevention. In line with good corporate governance practices, all cases
of whistle blowing will also be reported to and reviewed by the Companys Audit
Committee (AC). For cases involving the CEO or CFO, the investigation undertaken by
the Investigation Committee will be chaired by the AC Chairman or his delegated
appointee.

f.

Upon closure of each whistle blowing case, the Investigation Committee would decide if
it is in the interests of the Company and the whistle blower to make public the results of
the investigation to employees for their information purpose. The consent of the whistle
blower will also be taken into consideration.

Version History

Version

Responsible

Change Description

2.0

Lew Li Pheng

Extension of whistle
external individuals

StarHub Ltd.

Internal Use

Change
Request#
blowers

to

Date
1 Nov 13

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