All levels of personnel throughout the TSH Group have the responsibility for dealing with fraud risk. The Board and management are collectively responsible for the prevention and detection of fraud.
All employees are encouraged to raise genuine concerns about possible improprieties in matters of financial reporting, compliance and other malpractices at the earliest opportunity, and in an appropriate way.
This policy is designed to:
This policy not only covers possible improprieties in matters of financial reporting, but also:
The principles underpinning the policy are as follows:
If employees feel the matter is so serious that it cannot be discussed with any of the above, they should contact the Senior Independent Non-Executive Director, being the Director identified in Section 1.1.3 of this Guide and the Company’s annual report as one to whom concerns may be conveyed.
The concern must be raised in writing and the matter will be regarded as strictly confidential. The background and history of the concern, giving names, dates and places where possible should be set out and the reason why the employee is particularly concerned about the situation. Although the employee is not expected to prove the truth of an allegation, he/she will need to demonstrate that there are sufficient grounds for concern.
Initial inquiries will be conducted to decide whether an investigation is appropriate and, if so, what form it should take. Some concerns may be resolved by agreed action without the need for investigation.
Employees’ identities will not be disclosed without prior consent. Where concerns cannot be resolved without revealing the identity of the employee raising the concern, a dialogue will be carried out with the said employee as to whether and how the matter can be proceeded.
The outcome of such investigation will be reported to the Board. Appropriate action will be taken to resolve the issue, which may result in disciplinary action, including dismissal or referral to the relevant authorities as the Board deemed fit. Subject to legal constraints, the employee raising the concern will be informed of the outcome of the investigation as soon as is practicable.