Whistleblower Policy

Effective: 20 January 2020

Overview

This Policy sets out the Skylink network reporting procedure on any whistleblower action in the Skylink network workplace premises.

Skylink network whistleblower policy promotes that the employees report on activities that they believe are illegal or dishonest to one or more concerned parties. We encourage and maintain the compliance obligations to all our employees, customers, and business partners, to raise serious concerns about violations of Skylink network’s code of conduct, health and safety policy, anti-bribery policy, or suspected violations of any law or regulations that govern Skylink network’s operations.

Scope

This policy applies to everyone who works at Skylink network in any capacity, full-time, part-time, or casual, including temporary employees and contractors.

Principles

The whistleblower is not responsible for investigating the activity or determining fault or corrective measures. Instead, the appropriate management officials authorized by Skylink network are charged with these responsibilities.

Skylink Network is dedicated to:

• Creating and widely publicizing whistle-blower protection policies with multiple avenues for reporting.
• Listening to the people who raise concern.
• Protecting those who report from unlawful retaliation.
• Maintaining their discretion and protecting their identities when requested.
• Investigating suspected offence or misconduct confidentially and impartially.
• Provide specific whistle-blower training for managers.
• Holding annual “Ethics and Compliance Day”.

What to Report

Skylink Network strongly encourages its employees to take action(s) promptly, when faced with non-compliance activity with any Skylink network policy or procedure, including but not limited to, Skylink’s Code of Conduct, Health and Safety Policy, Compliance Policy, Anti-bribery Policy or any other applicable law or regulation. Some situations may include:

• Financial fraud, criminal offence, any inappropriate financial transactions or practices that raise questions about Skylink network’s accounting, financial reporting, internal controls, or auditing practices.
• Misconduct of business practices and our Code of Conduct, which could constitute a conflict of interest.
• Corruption including payment of bribery or facilitation payments, unethical donations, gifts, or entertainment given to any business partners by Skylink network employees.
• Serious improper management including any breaches of occupational safety, concerns about environmental pollution, serious issues directed towards an employee (discrimination, violence, sexual assault, etc.) or serious violation of policies.

Skylink network Whistleblowing Reporting Systems are always available for employees, external suppliers, customers, and other parties with interests in the company, including where we serve our services. All reports must be treated equally per the reporting system, providing protection to those who report, it is only practicable for companies able to provide comprehensive protection to a restricted category of reporting persons.

It is in the best interest of Skylink network that breaches of the policies and rules are reported. For this reason, Skylink will not tolerate retaliation against anyone who reports non-compliance of any sort, regardless of whether or not their claims can be verified.

Note: The Whistleblower Policy is intended to encourage and enable management and employees to raise concerns within the organization for investigations and appropriate actions. With this goal in mind, no director or employee who, in good faith, reports a concern shall be threatened, discriminated or otherwise subject to retaliation or, in the case of an employee, no adverse employment consequences as a result of such report be made. Moreover, an employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including dismissal from the volunteer position or termination of employment.

Responsibility

The Whistleblower Policy shall be implemented by the Compliance Administrator or Designated Personnel to maintain security measurements set out within the Skylink network.

Compliance and Review

The Administration is responsible for establishing, overseeing, and assessing achievement against measurable objectives in relation to goals set out in this policy.

The Group’s Human Resources and Compliance Department is responsible for all other objectives and initiatives set out in this policy.

Infringement of this Policy

Skylink network has a long-standing commitment to conduct our business in compliance with all applicable local and international laws and regulations and in accordance with the highest ethical business principles and any violations of the policy will lead to disciplinary action up to and including dismissal of personnel/contract cancellation.

Further Information

For further information, contact with the Human Resources Department or Compliance Administrator.