Rickmers Maritime

Cargo Ship
headerwhistlepolicy


PROCEDURES

  1. Procedures for handling Complaints

    The procedures for the receipt, retention and treatment of a Complaint are set out below and shall be fully complied with.
  2. Submission of Complaint

    Every Complaint shall be in person or in writing and shall be lodged with either the CEO or CFO or any member of the Audit Committee ("AC") or Chairman of the AC. The Whistleblower must provide his/her particulars as follows:

    (a) Name
    (b) Department/Company
    (c) Contact Number and Email Address if available.

    The Complaint may not be attended to if the above-mentioned particulars are not stated. This policy requires Whistleblowers to put their names to allegations because appropriate follow-up questions and investigations may not be possible unless the source of the information is identified.
  3. Confidentiality of Identity

    Every effort will be made to protect the Whistleblower's identity. The identity of the Whistleblower shall be confidential save where:
    3.1 the identity of the Whistleblower, in the opinion of the AC, is material to any investigation.
    3.2 it is required by law, or by the order or directive of a court of law, regulatory body or by the Singapore Exchange or such other body that has the jurisdiction and authority of the law to require such identity to be revealed.
    3.3 the AC with the concurrence of the Board of Directors opined that it would be in the best interests of the Group to disclose the identity.
  4. Registration of Complaints

    The CEO, CFO and AC shall maintain or caused to be maintained a Complaints Register for the purposes of recording all Complaints received, the date of such Complaint and nature of such complaint. The AC shall approve making the Complaints Register available for inspection upon any request by investigating authorities.
  5. Dissemination of Documents

    The CFO shall make available to all employees a copy and shall brief all new employees of this Document including the latest update of the contact details of the AC.
  6. Determination by AC

    Upon receipt of any Complaint, the AC may:
    6.1 conduct its own investigation or review;
    6.2 instruct the Internal Auditor to conduct further investigations or review;
    6.3 instruct the relevant management to take such remedial action as it deems appropriate;
    6.4 engage such third parties as the AC may determine, to take remedial , to commence or conduct further investigations or review, as deem appropriate;
    6.5 report the matter to the authorities if there is reason to believe that a crime has been committed; and/or
    6.6 take any other action as AC may determine in the best interest of the Group.
  7. Review and Investigation of Complaint

    In the event that the AC conducts its own investigation or review, the AC shall:
    7.1 review and investigate the Complaint;
    7.2 inform Whistleblower of the likely timeline for a final response;
    7.3 recommend any remedial or legal action to be taken, where necessary; and
    7.4 notify Whistleblower of actions taken or reason(s) should it be decided that no action is to be taken.