WHISTLE BLOWING POLICY

I. POLICY STATEMENT

ASIA AMALGAMATED HOLDINGS CORPORATION (the "Company") is committed to conducting its business with honesty and integrity at all times. If, at any time, this commitment is not respected or appears to be in question, the Company will undertake to identify and remedy such situations. Therefore, it is the Company's policy to ensure that when a person has reasonable grounds to believe that an employee, manager or any other person related and/or involved in its business/operations has committed, or is about to commit, an offence that could harm the company's reputation, it denounces the wrongdoers in question.

The Whistle Blowing Policy has been put in place to:

  • Encourage employees, partners, contractors or managers to disclose the information or behavior;

  • Protecting complainants for retaliations;

  • Treat all parties to an investigation in a fair and impartial manner;

  • To ensure confidentiality as much as possible, and;

  • Take corrective and disciplinary action if wrongdoing(s) is/are discovered.

II. PURPOSE

The purpose of this policy is to encourage current and former employees, contractual third parties or partners and affiliates to communicate events that raise serious concerns about the Company. The Company encourages and will support persons who report illegal practices or individuals who violates the Company's existing policies and relevant laws.

III. SCOPE

This policy applies to all employees of the Company, as well as contractual third parties, partners or affiliates doing business with the company.

IV. REPORTING

It is the duty of all concern (as reference in SCOPE) to report all misconduct or suspected misconduct, including fraud and financial impropriety to the Board. This includes misconduct such as but not limited to the ff:

  • Providing false or misleading information, or withholding material information of the Company's financial statements, accounting, auditing, or any other reporting fraud and misrepresentation;

  • Pursuit material benefit or advantage in violation of the Company's Conflict of Interest policy;

  • Misappropriation or misuse of the Company's resources such as funds, supplies or other assets;

  • Unauthorized alteration or manipulation of computer files;

  • Destroying, altering, mutilating, concealing, covering-up, falsifying or making false entries in any records that may be connected to an official proceeding, in violation of related laws or regulations, or otherwise obstructing, influencing or impending any official proceeding;

  • Violation of related laws or regulations that could result in fines or civil damages payable by the Company the could otherwise significantly harm its reputation or public image;

  • Unethical business conduct in violation of the Company's policies and/or Code of Business and Ethics;

  • Danger to health, safety, or well-being of employees and/or the general public;

  • Forgery or alteration of documents;

  • Authorizing or receiving compensation for goods not received or services not performed or paying for services or goods that are not or were not rendered or delivered;

  • Authorizing or receiving compensation for hours not worked;

  • Embezzling, self-dealing or otherwise obtaining an unlawful private benefit for the Company;

  • Assets being used by anyone in the organization improperly for personal gain, and;

  • Human rights violations and exploitation of employees.

V. ACTING IN GOOD FAITH

  • Any person who files a complaint alleging misconduct must act in good faith and have reasonable grounds to believe that the information disclosed indicates wrongdoings, and;

  • No employee, contractor, partner or affiliates, who make a denunciation in good faith, will be subject to retaliation. Retaliation in any form against a person who has reported a violation will never be condoned or allowed by the Company. Anyone who retaliates against a person who has a reported a violation or any wrongdoing in good faith is subject to disciplinary action up to and including dismissal.

VI. PROCEDURE

A complaint may be submitted directly or anonymously, in writing or otherwise thru e-mail to:

BELINDA T. BATUEGAS
105 Cuenco Street, Santo Domingo, Quezon City
Mobile# 0912-2234157
Or
Email@ belindabatuegas@yahoo.com

Note : The above-mentioned person will then forward such report to the Compliance Officer or Corporate Secretary as soon as the alleged reported matter is validated and supported. The Compliance Officer or Corporate Secretary will then convene the Compliance Panel and will serve as the investigative body to evaluate further the submitted complaint.

The written statement for the complaint must contain the following:

  1. Description of the offense;

  2. Date on which the complaint became aware of the offense;

  3. Name of the person suspected in committing the offense, and;

  4. Actions taken (if applicable) before filing a complaint.

  • The complainant will not be dismissed, demoted, suspended, threatened, harassed or otherwise discriminated against because of the complaint of genuine concern. Any employees of the Company who contravenes this policy when dealing with a complainant may be dismissed. Similarly, any member of the Board who violates this policy on his or her dealing with a complainant may have his or her relationship with the Company terminated.

  • A person is not required to prove the truth of an allegation but is required to act in good faith and provide sufficient evidences to the person contacted to demonstrate that there are sufficient grounds for the complaint. The number of contacts between the complainant and the investigative party will depend on the nature of the question and the clarity of the information provided. The investigative body may request additional information for the complaint.

  • All complaints will be treated in a confidential and sensitive manner. In addition, the complainant must be able to remain anonymous, except in cases where the nature of the disclosure and/or resulting investigation makes it necessary to reveal such identity. In such cases, all reasonable measures must be taken to protect the complainant from any prejudice resulting from a disclosure.

VII. INVESTIGATION

All relevant cases, including suspicious but unproven one, will be reviewed and analyzed thoroughly by the investigative body. All investigations will be kept confidential to the extent possible. Appropriate corrective actions will be taken, if necessary, and the findings will be communicated to the whistle blower and its superior from time to time as the case(s) progresses.

This policy (Whistle Blower Policy) shall take effect immediately upon the Boards approval and shall supersede all existing policies inconsistent with the intention and mandate herein stated.