PROCESS Ref No.

DOC AS/MS/053/15
Rev No. 0

Whistle Blowing Date : 2015

Procedure Approved by
Chief Executive
Officer

This Procedure applies to all employees, former employees and contract workers working with ASAATCO
or its sub-contractors.
The purpose of this procedure is to provide a framework to promote responsible whistle blowing.
Whistle blowing is the reporting by workers of any malpractice or illegal act or omission by other
workers

1 Relationship of this procedure to ASAATCO’s other policies and

procedures
ASAATCO policies and procedures on grievance, discipline, harassment, etc. should be used in most
situations. The use of this procedure should be restricted to where you reasonably believe one of the
following has occurred, is occurring or is likely to occur:
 A criminal offense, including fraud
 Disregard for legislation, particularly in relation to health and safety at work\malpractice, or ill
treatment of a customer or supplier by a member of staff
 Serious damage to the environment
 Any other serious irregularity, or
 Deliberate concealment of any of the above
Whistle blowing should not be used in place of ASAATCO grievance procedures or be a route for raising
malicious of unfounded allegations. Only those who use this policy in good faith will be protected under
it

2 The procedure
The designated officers
The following people are the designated officers under this procedure. They have direct access to the
CEO of ASAATCO
Jaya Prabhal
HSE Advisor
Biju M P
Logistics Coordinator

3 Raising a concern
3.1 The Line Manager Route
You should normally raise concerns about wrongdoing and malpractice with your immediate manager
first, who will notify the matter to one of the Designated Officers
 PROCESS Ref No. DOC AS/MS/053/15
Rev No. 0

Whistle Blowing Date : 2015

Procedure Approved by
Chief Executive
Officer

3.2 The Head Officer Route

If you consider it more appropriate to raise your concern, in the first instance, with a manager of
ASAATCO, other than the Designated Officers, then please do so and he or she will notify one of the
Designated Officers

3.3 The Designated Officer Route

If the matter is of a very serious nature, such as an allegation of fraud involving an ASAATCO Manager,
or if it involves your immediate manager, you may notify one of the Designated Officers directly

4 The Investigative stages

The designated officer, possibly in conjunction with the CEO, will arrange a meeting with you to give
feedback on the investigation. This will not include details of any disciplinary action, which will remain
confidential to the individual concerned. The feedback will be provided within 10 working days of the
conclusion of the investigation and any inquiry.
If you are not satisfied with the outcome of the investigation, ASAATCO recognises your right to make
disclosures to prescribed regulators (PDO, ROP, RSST, MOM) where justified

5 The law
If it is deemed after investigation that any laws are being broken the case will be handed to the
ROP/MOM to be dealt with

6 Protection of whistle blowers

ASAATCO will not tolerate any harassment, victimisation or discrimination of a good faith whistle blower
and will treat this as a serious disciplinary offense.