The purpose of this policy aims to provide an avenue for employees to raise concerns and provide guidelines for handling these concerns. The scope of this policy covers the reporting and investigation of improper or illegal activities at HNF. The definitions used for the purpose of this policy are as follows:

This policy aims to guide whistle-blowing procedures stems from HNF’s commitment to developing a culture of openness, accountability, and integrity.

HNF encourages their employees who have concerns about suspected serious misconduct or any breach or suspected breach of law or regulation that may adversely impact the organisation to come forward and raise the concerns.

The policy also enables the Board of Management to be informed at an early stage about acts of misconduct.

Reports can be made against acts that are not in line with the organisation’s values, deviating from HNF’s Code of Conduct and Ethical Standards. Reports can include but are not limited to the following categories:

• Endangerment or likely endangerment of health or safety of any individual
• Negligence of duty
• Discrimination or physical abuse of staff or service recipients
• Misappropriation of funds
• Fraud or suspected fraud, thefts, and dishonest acts
• Profiteering as a result of insider knowledge
• Conflict of interest in any activity that is opposed to the best interest of HNF
• Disclosure of confidential information to outside parties
• Intimidation or harassment of staff and other persons during the course of work or in the capacity as a HNF employee.
• Information relating to any of the above being deliberately concealed or attempts are being made to conceal the same.

Only disclosed reporting (i.e. disclosure where the whistleblower identifies himself / herself) will be handled and investigated.

Whistle-blowers can choose to report their concerns by means of writing, email, or in-person. However, formal investigations will only begin after a written report is being filed by the whistle-blower.

The whistle-blower should report concerns to the Chief Executive Officer (CEO). In the case where the CEO is being implicated or otherwise involved in the concern, the whistle-blower should approach the Chairman of the Audit & Risk Committee.

Reporting of concerns should be performed in good faith. Good faith is interpreted from a report made without malice or consideration of personal benefit, and where the employee is reasonable in believing his/her concerns to be valid. Employees who knowingly or carelessly make disclosures that are not in good faith may be subject to disciplinary procedures. Reporting with malicious intent will not be tolerated.

Whistle-blowees have a duty to cooperate with investigators. The whistle-blowees’ refusal to cooperate with the investigators may lead to actions to be taken against him/her.

All parties who are asked to provide information have a duty to fully cooperate. They should refrain from discussing matters concerning the investigations to others.

The whistle-blower’s identity will be kept confidential unless required by the court or other regulatory authorities to disclose the identity. Victimization of the whistle-blower will not be tolerated and disciplinary action will be taken against those who do so.

The whistle-blowee’s identity will be kept confidential until there is sufficient evidence to support that it is a genuine case.

The Management reserves the right to make any decision based on the findings of the investigation. After a formal written report is being filed with the relevant senior staff, a written acknowledgement may be sent to the whistle-blower by the CE or Chairman of Audit & Risk Committee (should the report implicate the CEO).

The case is to be highlighted by the CEO / Chairman of Audit & Risk Committee to appropriate members of the Management or Board of Management to assist in the investigation on a need-to-know basis. The number of staff involved in the investigation will be kept to a minimum so as to ensure that confidentiality of the case is maintained.