i. The Whistleblowing Policy is formulated to protect the values of transparency, integrity, impartiality and accountability in where TERAJU conducts its businesses and affairs. Employees are encouraged to blow the whistle, in good faith, on any such potential violations or concerns according to the procedures established in this Whistleblowing Policy.

ii. Employees who blow the whistle on wrongdoings will be protected against victimisation or other adverse treatment provided that the whistleblowing is done in good faith. However, any whistleblowing which is not made in good faith and is found to be deliberately falsified with malicious intent will be subjected to Disciplinary Action by the
Company. All employees must follow this Whistleblowing Policy and cooperate with any review and investigation initiated pursuant to this Whistleblowing Policy.

iii. TERAJU’s Whistleblowing Policy will:

• Govern the process through which employees and others may report potential violations or concerns relating to relevant laws, rules, regulations, business ethics and conduct, including any violations or concerns relating to illegal, immoral, embezzlement and fraudulent activities;
• Establish a mechanism for responding to any reports from employees and others regarding such potential violations or concerns;
• Prohibit retaliation against employees raising such potential violations or concerns; and
• Establish procedures for the retention of records of reports.

Examples of wrongdoing include, but are not limited to, fraud, including financial fraud and accounting fraud, violation of laws and regulations, violations of Company policies, unethical behaviour or practices, endangerment to public health or safety and negligence of duty.

A qualified disclosure may be made if it relates to one or more of the following wrongdoings by any employees in the conduct of TERAJU’s business or affairs that is being, has been, or is likely to be committed

• Failure to comply with legal obligations;
• Criminal offence;
• Corruption or fraud;

Misuse or abuse of TERAJU’s funds or assets;

• Gross mismanagement within TERAJU;
• Serious financial irregularity or impropriety within TERAJU;
• Repeated ill treatment of a client/customer/supplier or any other party despite a complaint being made;
• Serious breach of TERAJU’s Company’s Policy, Code of Ethics
  or Conflict of Interest Code for its employees and directors;
• Actions which endanger the health or safety of employees or the public;
• Failure to comply with the provisions of the Government Laws
  and Regulations where the wrongdoer, knowingly, disregards
  or does not comply with such provisions;
• Knowingly directing or advising a person to commit any of the
  above wrongdoings; and
• Any action which is intended to conceal any of the above.

The above list is not exhaustive and there will be instances where employees would need to exercise judgement.

An employee will not be expected to prove the truth of an allegation but he or she should be able to demonstrate that there are sufficient grounds to have a reasonable belief that something is wrong and are reported on good faith.

Good faith is evident when the report is made without malice or consideration of personal benefit and the employee has a reasonable basis to believe that the report is true; provided, however, a report does
not have to be proven to be true to be made in good faith. Good faith is lacking when the disclosure is known to be malicious or false.

Any employee, customer, suppliers, or third parties may submit reports against an employee or the management, if indeed there were acts of wrongdoing being committed.

The whistle blower may register any wrong doing/act committed by the
Staff/Management of the TERAJU via the following channels: –

• i) Chief Executive Officer (CEO)
• ii) Head of Department (Head of Department)
• iii) Head of Division
• iv) Head of HR

The whistle blower shall file a report with details of the matters concerned. The report will be treated in the strictest of confidence and no action shall be taken against the whistle blower in accordance with the Whistleblower Protection Act 2010.

Action to investigate the matter shall be maintain confidential to protect the identity and assurance action will be taken to investigate promptly.

If the allegation has a financial impact or would cause damage to the reputation or embarrassment to the company, HR shall escalate the matters to the CEO.

If the allegation does not concern the CEO, then the CEO will also be alerted concurrently. If the allegation concerns the CEO, the HR shall direct the investigation to Board of Trustee (BOT).

Submission of Complaints
Any person, including employees, with a concern or complaint may submit their concern or complaint to any of the Head of Department (HOD) or CEO via telephone call, mail, or through email. The recipient shall escalate the concern or complaint to HR Department within three
(3) working days.

The person submitting a complaint should include a contact number and/or address in the submission at which he or she may be contacted if the person requests to be contacted.

Any person, including employees, with a concern or complaint may submit their concern or complaint to any of the Head of Department (HOD) or CEO via telephone call, mail, or through email. The recipient shall escalate the concern or complaint to HR Department within three
(3) working days.

The person submitting a complaint should include a contact number and/or address in the submission at which he or she may be contacted if the person requests to be contacted.

The HR shall maintain a log of all concerns or complaints, tracking their receipt, investigation and resolution. Records shall be maintain for seven (7) years.

CEO and the respective Head of Departments are to ensure that all employees understand and acknowledge the importance and need for Whistleblower Procedure. It is to ensure TERAJU conduct its business with the highest standard of integrity and honesty and in fulfilling its mission/objective.