This Whistleblower Policy Statement is established to foster an environment in which employees and stakeholders can report suspected wrongdoing without fear of retaliation. The objectives of this policy are as follows:
- To encourage employees and stakeholders to report actual, suspected, or potential misconduct promptly.
- To delineate clear procedures for the submission and resolution of such concerns.
- To afford protection to whistleblowers against any form of retaliation, and to guarantee that their reports are treated with the utmost respect and confidentiality.
- To reinforce a corporate culture characterized by openness, accountability, and ethical conduct.
This policy shall apply to:
- All employees, officers, and directors of the corporation;
- Suppliers, contractors, consultants, and agents engaged by the corporation;
- Shareholders and other stakeholders possessing knowledge of, or access to, information regarding the corporation’s operations.
Reportable Concerns
Issues that may be reported pursuant to this policy include, but are not limited to, the following:
- Fraud, bribery, corruption, and other acts of financial impropriety;
- Theft, embezzlement, or misappropriation of corporate assets;
- Violations of legal or regulatory requirements, including those issued by the Securities and Exchange Commission of the Philippines and other pertinent authorities;
- Breaches of the corporation’s code of conduct, ethics policy, or any internal policies;
- Harassment, discrimination, or abuse occurring within the workplace;
- Infringements relating to health, safety, or the environment;
- Any other acts deemed improper, unethical, or unlawful.
Reporting Mechanisms
The corporation is committed to providing multiple, accessible avenues for the reporting of concerns, which may include:
- Direct communication with immediate supervisors or managers;
- Utilization of dedicated whistleblower hotlines (telephone, email, or web-based platforms);
- Submission of reports to the Human Resources or Compliance Department;
- Anonymous reporting mechanisms, subject to feasibility.
All submissions shall be managed with the highest degree of sensitivity and confidentiality.
Confidentiality
The corporation recognizes the paramount importance of confidentiality in whistleblower matters. All reports, investigations, and subsequent outcomes shall be administered in a manner that safeguards the identities of whistleblowers and all involved parties to the greatest extent possible. Disclosure of information shall be restricted exclusively to those individuals whose familiarity with the details is requisite for the conduct of a thorough and impartial investigation, or as mandated by law.
Non-Retaliation
The corporation unequivocally prohibits retaliation of any kind against individuals who, in good faith, report concerns or participate in investigations. Retaliatory acts may include, but are not limited to, dismissal, demotion, harassment, discrimination, or any adverse employment action. Any individual found to have engaged in retaliatory conduct shall be subject to disciplinary measures, including but not limited to termination of employment or contractual arrangements. Whistleblowers who believe they have been subjected to retaliation may report their concerns to the Compliance Department or any duly authorized body.
Good Faith Requirement
Whistleblowers are expected to act with sincerity and honesty, supplying information believed to be truthful and accurate. Reports that are malicious, frivolous, or knowingly false may result in appropriate disciplinary action.
Investigation Procedures
Upon receipt of a whistleblower report, the corporation shall:
- Acknowledge the receipt of the concern, where appropriate, and if the whistleblower’s identity is known.
- Conduct a preliminary assessment to ascertain whether a formal investigation is warranted.
- Appoint an impartial investigator or investigatory team.
- Collect and analyze relevant facts, conduct interviews with pertinent parties, and review supporting documentation.
- Maintain strict confidentiality throughout the investigation process.
- Document findings and recommend corrective or disciplinary actions, where necessary.
- Communicate the results of the investigation to the whistleblower, where appropriate and feasible.
Protection of Rights
The corporation is steadfast in its commitment to protecting the legal rights of both whistleblowers and individuals accused of misconduct. All parties shall be treated equitably, and investigations shall be conducted impartially and without prejudice.
Roles and Responsibilities
- Employees and Stakeholders: Responsible for reporting concerns and cooperating fully with investigations.
- Managers and Supervisors: Obliged to foster an environment conducive to openness and to support those who raise legitimate concerns.
- Compliance/HR Department: Charged with receiving, documenting, investigating, and resolving whistleblower reports.
- Board of Directors: Entrusted with oversight of the implementation and ongoing effectiveness of this policy.
Training and Awareness
The corporation shall ensure that all employees and relevant stakeholders are apprised of this policy and comprehend their attendant rights and responsibilities. Periodic training sessions, policy briefings, and access to necessary resources shall be provided to promote a culture of transparency and ethical conduct.
Review and Amendments
This policy shall be reviewed periodically to ensure its continuing effectiveness and alignment with evolving legal and regulatory requirements. Amendments may be instituted as deemed necessary, subject to approval by the Board of Directors or the appropriate governing authority.
Policy Communication
This Whistleblower Policy Statement shall be disseminated and made accessible to all employees and stakeholders. Its provisions shall be communicated regularly through internal memoranda, training sessions, and official corporate channels.
Legal Basis
This policy is grounded in the pertinent provisions of the Philippine Labor Code, Republic Act No. 11032 (Ease of Doing Business and Efficient Government Service Delivery Act), Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), and all other relevant laws, rules, and guidelines governing corporate conduct and employee protection within the Philippines.
Statement of Commitment
The corporation hereby affirms its unwavering commitment to fostering a professional environment in which concerns may be raised freely and responsibly. By consistently upholding the highest standards of ethical behavior and accountability, the corporation ensures its long-term growth, reputation, and success within the Philippine business community.
To report any concerns, please send an email to: CRISPCompliance@crisp.com.ph.