Policy Objective

Univanich Palm Oil Public Company Limited (“the Company”) has established a Whistle Blowing Policy to support and provide opportunities for stakeholders. Internal and external sources are able to report clues or complaints about unethical behaviour related to the company. Occurrences such as corruption, violation of company regulations, unethical practices, or other illegal acts can be reported to the company committee to be investigated and solution implemented accordingly. Reporters with legitimate complaints are assured protection from the company and immune to external response measures.

The objective of having a written and formal policy is to act as a precautionary measure to prevent and deter future premature misconducts, as well as supporting transparency, justice, and the promotion of a good working environment.

Contact channel for whistleblowing or making complaints

If the complainant notices or suspects any wrongdoing, the complainant can notify the committee via various channels as follows:

Contact channel for whistleblowing or making complaints

Examples of offences that can be complained include, but not limited to:

  • Criminal offences or advocacy for an offence
  • Failure to comply with laws or regulations
  • Forgery of financial statements, documents, embezzlement or use of company funds without authorization
  • Violations of clearly communicated work procedures in the form of company policies, regulations or rules
  • Cases of fraud and corruption
  • Cases of bullying colleagues or treating unfairly towards others
  • Cases of harm to the health or safety of any person
  • Cases of damage to the environment
  • Detrimental behaviour or unethical behaviour
  • Sexual abuse, whether physical or verbal
  • Leakage of company secrets

Details of whistleblowing and complaints must be true and sufficient for the company to continue the investigation. The complainants will receive assured protection by the company and immune to external threats. Complaint information obtained will be treated with utmost confidentiality, and will only be disclosed as necessary. The company will mainly consider the safety and potential damages to the complainant, and the name will not be disclosed without the consent of the whistleblower.

If the complainant is under risk for possible ramifications and damages, the company will establish and implement safeguards and policies to protect such individuals or groups. In the case of complainants receiving threats or ramifications, the company will support and compensate the complainants with fair and just procedures. These measures will only be used in cases where the complainant has pure intentions and the disclosure is in good faith.

If the complaints are investigated and found to be slander, defamation, or false statements for personal gain, the company will treat it as a disciplinary offence and corrupt behaviour. In this case, the company will implement serious disciplinary measures to the complainant. If the complainant is an employee of Univanich, the company will punish according to the regulations of the company accordingly. In the case of a complainant originating from external sources, the complainant will be notified, and legal proceedings will be issued.

The operational process when receiving complaints

  1. When the Operations Committee receives information on reports of wrongdoing and fraud, an investigation department will be established to carry out the collection of evidence and facts in the processing and judgement of wrongdoing. The appointed persons must not be involved in or having interests in matters that are related to the complaint.
  2. The investigation department will investigate the facts through the collection of evidence and questioning witnesses and the reported.
  3. The operational committee will call a meeting with the investigation department to analyze such information and evidence collected, and consider appropriate steps in furthering the investigation in order to maintain confidentiality and limitations of the law. If in this step there is not enough evidence collected or there is no evidence, the case may be dropped.
  4. If the case has substance and requires further investigation such as coordination with the police department, or external legal issues, the operational committee will coordinate with external law departments and continue the investigation.
  5. The operational committee will produce a report for the complainant if he/she chooses to disclose their identity. If not, the operational committee will report to the Management Committee or Board of Directors, depending on the severity of the case.
  6. The operational committee will produce penalties for those who have done wrong or compensate those who have been damaged/impacted.

Measures for the protection of complainants

The company has the policy to accept complaints both anonymously and non-anonymously. In both cases, the company will keep the name and identity of the complainant throughout the process as confidential as possible in order to prevent the complainant from harassment, intimidation, harm or impact of any relationship at work.

If in the event with the necessity to disclose information, name or identity of the complainant such as disclosure of further information to give to authorities, testimonies or attending hearings, the company will limit the number of people involved to as little as possible. Appropriate protection measures for the complainant will also be assured.

If the complainant is affected by the complaint or damaged in any way related to the complaint, the complainant can notify the company. In such cases, the company will compensate for appropriate damages or prescribing safeguard measures in order to protect the complainant.