Video & Slides 
Whistle-blower Policy
Introduction
All Company employees; smallholders; contractors; consultants; family members of employees; nearby villagers at one time or another may have concerns about what is happening at the workplace. Usually, these concerns are easily resolved. However, when they are about unlawful conduct, financial malpractice or dangers to the public or the environment or harassment or misbehaviour at work, it can be difficult to know what to do.
You may be worried about raising such issues or may want to keep the concerns to yourself, perhaps feeling it’s none of your business or that it’s only a suspicion. You may feel that raising the matter would be disloyal to colleagues, managers or to the organisation. You may decide to say something but find that you have spoken to the wrong person or raised the issue in the wrong way and are not sure what to do next.
Univanich takes very seriously any form of malpractice and has introduced this procedure to enable you to raise your concerns about such malpractice at an early stage and in the right way. We would rather that you raised the matter when it is just a concern rather than wait for proof.
If something is troubling you, which you think the company should know about or look into, please use this procedure.
“Whistleblowing” is a process of reporting matters of concern that have not or are not being dealt with adequately by normal processes.
These include (but this is not an exclusive list):
- • Conduct which is a criminal offence or a breach of law
- • Unauthorised use of company funds
- • Possible fraud and corruption
- • Damage to the environment
- • Health and safety risks of any individual
- • Unethical conduct
- • Disclosures related to miscarriages of justice
- • Sexual, physical or verbal abuse
Other procedures are available to employees e.g. The Grievance procedure which relates to complaints about your own employment The simple rule is if in doubt – raise it, because Univanich views a whistle-blower as a witness, not a complainant.
Purpose
The main purpose of this whistle-blowing policy is to give effect to Univanich’s duty of care as a responsible employer and good corporate citizen.
Therefore, this document sets out Univanich’s written, formal whistle-blowing policy, consisting of safe and effective procedures for misconduct disclosure or reporting so that appropriate remedial action can be taken.
A written, formal policy, properly communicated, is also a means of preventing and deterring misconduct that might be contemplated but has not yet taken place.
A written, formal policy is also a transparent method of addressing issues relating to whistle-blowing, such as answering standard questions, giving assurances, providing information, and offering explanations.
The purpose of this policy is to encourage and enable all employees and others associated with the company to speak out about violations of policy, or any other matter that brings the good name of the Company into disrepute. Those who report violations of policy are assured that their disclosures will remain confidential and will not result in reprisals or retaliation that could impact upon their own security of employment.
The person making a protected disclosure is commonly referred to as a ‘Whistle-blower’. ‘Whistle-blowers’ may be Company employees; smallholders; consultants; contractors; family members of employees; residents of nearby villages (close to Univanich operational units) or the officers of any members association representing one or more of these groups..
Scope
A fundamental requirement of all employees, and representatives of Univanich, is to comply with all relevant laws of the country of operations (Thailand or Philippines) and to act with honesty and integrity when fulfilling their responsibilities to the Company. As individuals, all employees are expected to display the highest standards of business and personal behaviour at the workplace and in any circumstances where they can be regarded as representing or representative of the Company. It is a responsibility of every employee, to report violations of Company policy or any other matter that may bring the good name of the Company into disrepute. Such disclosures will be regarded as ‘Whistle Blowing’, meaning that the disclosures are confidential and protected from reprisal.
UNIVANICH’S ASSURANCE TO YOU
The Univanich Board and the Chief Executive Officer are committed to this policy. If you raise a genuine concern under this Policy, you will not be at risk of losing your job or suffering any form of retribution as a result. Provided you are acting in good faith, it does not matter if you are mistaken. Of course, we do not extend this assurance to someone who maliciously raises a matter they know is untrue.
No employee, smallholder, contractor, consultant family member of an employee, or officer of an association representing one or more of these groups, who in good faith reports a violation of policy shall suffer harassment, retaliation or threats to their continued employment.
Univanich will not tolerate the harassment or victimisation of anyone raising a genuine concern. Any member of management who retaliates against someone who has in good faith reported a policy violation, or who applies sanctions or pressure that can be interpreted as harassment of the employee making the disclosure; will be subject to disciplinary action including possible termination of employment for breaching the ‘Whistle-blower’ policy.
We recognise that you may nonetheless want to raise a concern in confidence under this Policy. If you ask us to protect your identity by keeping your confidence, we will not disclose it without your consent. If the situation arises where we are not able to resolve the concern without revealing your identity (for instance because your evidence is needed in court), we will discuss with you whether and how we can proceed.
Remember that if you do not tell us who you are, it will be much more difficult for us to look into the matter or to protect your position or to give you feedback. Accordingly, while we will consider anonymous reports, this Policy is not appropriate for concerns raised anonymously.
IMPLEMENTATION (How we will handle the matter)
Once you have told us of your concern, we will look into it to assess initially what action should be taken. This may involve an internal inquiry or a more formal investigation. We will tell you who is handling the matter, how you can contact him/her and whether your further assistance may be needed. If you request, we will write to you summarizing your concern and setting out how we propose to handle it.
When you raise the concern, you may be asked how you think the matter might best be resolved. If you do have any personal interest in the matter, we do ask that you tell us at the outset. If your concern falls more properly within the Grievance Procedure, we will tell you.
While the purpose of this Policy is to enable us to investigate possible malpractice and take appropriate steps to deal with it, we will give you as much feedback as we properly can. If requested, we will confirm our response to you in writing. However, we may not be able to tell you the precise action we’ve taken where this would infringe a duty of confidence owed by us to someone else.
Every case reported will be recorded with details of the outcomes. The records will be presented to the Audit Committee for review.
HOW TO RAISE A CONCERN
If you have a concern about any malpractice, for employees we hope you will feel able to raise if first with your Line Manager. In most cases, an employee’s line manager is the best person to listen and respond to employees’ concerns.
For people outside the company then we refer you to our designated officers. A report to the designated officer can be made verbally, electronically and or by mail.
For employees, if you feel unable to raise the matter with your Line Manager, for whatever reason, please raise the matter directly to the Designated Officer (DO) who has been individually charged to apply and ensure compliance with this policy. These DOs shall be named on all Company Notice Boards. Please say if you want to raise the matter in confidence so that they can make appropriate arrangements.
For any fraud related cases we ask for the information to be sent by mail to The
Chairman of Audit Committee, using the company address.
Univanich Designated Officers.
Mr.Anek Pana-apichon Chairman of Audit Committee
Harry Brock Chief Executive Officer
Nattapong Dachanabhirom Chief Financial Officer
Natcha Sornnirun Human Resource Officer
Company Address: 258 Aoluk- Laemsak Rd.Aoluk-tai, Aoluk Krabi 81110
We recognize that in certain situations, employees may want to speak to another person in the company with whom they feel comfortable discussing the issue.
If a member of management is approached by an employee, smallholder, contractor, consultant, family member of an employee, or officer of an association representing one or more of these groups, who wishes to report alleged violations of Company policy. The member of management is required to forward details of that report and their response to one of the DOs.
Because DOs
Have been trained
Are responsible for recording and investigating allegations
Have been assigned the authority and discretion to pursue this policy
Will provide feedback to you on the outcome
If these channels have been followed and you still have concerns, or if you feel that the matter is so serious that you cannot discuss it with any of the above,
please contact: the CEO directly.
IF YOU ARE DISSATISFIED
This policy is intended to provide you with an avenue within Univanich to raise concerns. Univanich hopes you will be satisfied with any action taken. If you are not, and if you feel it is right to take the matter further, the following are possible contact points:
- The Univanich Audit Committee members
- Chairman of the Board of Univanich
If you do take the matter outside of the company, you should ensure that you do not disclose confidential information.
With thanks and kind regards,
Harry Brock
Chief Executive Officer
Ph +66 (75) 681126-8 Ext 111
E-mail harry.brock@univanich.com
