Purpose

Our Employee Code of Conduct Policy outlines our expectations regarding employees’ behavior towards their colleagues, supervisors, and overall organization.

We promote freedom of expression and open communication. But we expect all employees to follow our code of conduct. They should avoid offending, bullying, participating in serious disputes and disrupting our workplace. We also expect them to foster a well-organized, respectful, and collaborative environment.

Awareness of the provisions of this Code is fundamental in ensuring employees act appropriately in all dealings involving the Company.

Scope

This policy applies to all our employees regardless of employment agreement or rank.

Policy Elements

Compliance with law

All employees must protect our company’s legality. They should comply with all environmental, safety and health and fair dealing laws. We expect employees to be ethical and responsible when dealing with our company’s finances, products, and public image.

Respect in the workplace

All employees should respect their colleagues. Any kind of discriminatory behavior, bully, harassment, or victimization is strictly prohibited. Employees should conform with our equal opportunity policy in all aspects of their work, from recruitment and performance evaluation to interpersonal relations.

Protection of Company Property

All employees should treat our company’s property, whether material or intangible, with respect and care.

Employees:

·       Should not misuse company equipment or use it frivolously or use for individual purposes. E.g.: Use company equipment to make profit without permission.

·       Should respect all kinds of incorporeal property. This includes logo and other property such as information, technical report etc. Employees should only use them for their job duties purposes.

Employees should protect company facilities and other material property including company cars from damage and vandalism, whenever possible.

 Professionalism

All employees must show integrity and professionalism in the workplace:

·       Corruption

We discourage employees from accepting gifts from clients or partners. We prohibit briberies for the benefit of any external or internal party.

·       Job duties and authority

All employees should fulfill their job duties with integrity and respect toward customers and the community. Supervisors and managers must not abuse their authority. We expect them to delegate duties to their team members considering their competences and workload. Likewise, we expect team members to follow team leaders’ instructions and complete their duties with skill and in a timely manner.

We encourage mentoring throughout our company.

·       Conflict of interest

We expect employees to avoid any personal, financial, or other interests that might hinder their capability or willingness to perform their job duties.

·       Teamwork

Employees should be friendly and collaborative. They should try not to disrupt the workplace or present obstacles to their colleagues’ work.

 ·       Communication

All employees must be open for communication with their colleagues, supervisors or team members.

·       Benefits

We expect employees to not abuse their employment benefits. This can refer to time off, insurance, facilities, or other benefits our company offers.

·       Policies

All employees should read and follow our company policies. If they have any questions or need any clarification, they should ask their managers or Human Resource (HR) department.

Disciplinary Actions

Our company may have to take disciplinary action against employees who repeatedly or intentionally fail to follow our code of conduct. Disciplinary actions will vary depending on the violation.

1. Purpose

This Policy exists to act as a source of information and guidance for those working for GTS. It helps them recognize and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy Statement

 2.1       GTS is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. GTS has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2       GTS will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws but not limited to the Malaysian Penal Code (revised 1977), the Malaysian Anti-Corruption Commission Act 2009 (revised 2018), the Malaysian Companies Act 2016 and the Australian Criminal Code Act 1995, in regards to our conduct both at home and abroad.

2.3       This Policy is applicable globally. If our Personnel are travelling outside of Malaysia, our Personnel are subject to the laws of the country our Personnel are in, but the principles of this Policy must be adhered to regardless of whether or not that country has specific anti-bribery or anti-corruption laws. In cases where there is a conflict between the specific anti-bribery and anti-corruption laws and the principles contained in this Policy, the stricter provision shall prevail.

2.4       GTS recognizes that bribery and corruption are punishable by up to twenty (20) years of imprisonment and a fine of unlimited amount according to the Malaysian Anti-Corruption Commission Act 2009 (revised 2018) (“MACC Act”). If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.

3. Policy Coverage

 3.1       This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where our Personnel are located (within or outside of Malaysia). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

3.2       In the context of this policy, third-party refers to any individual or organization our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3       Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

4. Definition of Bribery

 4.1       Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

4.2       A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3       Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and accept it, this also breaking the law.

4.4       Bribery is illegal. Our Personnel must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). Our Personnel must not bribe a foreign public official anywhere in the world. Our Personnel must not accept bribes in any degree and if there is uncertainty about whether something is a bribe or a gift or act of hospitality, our Personnel must seek further advice from the company’s director.

5. Anti-Bribery And Anti-Corruption

 5.1        The MACC Act stipulates four (4) main offences, being:

•      Soliciting / Receiving Gratification (Bribe) – Sections 16 & 17(a) MACC Act

•      Offering / Giving Gratification (Bribe) – Section 17(b) MACC Act

•      Intending to Deceive (False Claim) – Section 18 MACC Act

•      Using Office or Position for Gratification (Bribe) (Abuse of Power / Position) – Section 23 MACC Act

The Malaysian Anti-Corruption Commission (Amendment) Act 2018, which will be in force on 1 June 2020 introduces two (2) more offences, being:

•      Offering / Giving Gratification by commercial organisation (Corporate Liability) – Section 17A MACC Act

•      Deemed Parallel Personal Liability for Senior Personnel (Personal Liability) – Section 17A(3) MACC Act

5.2      Gifts and hospitality

GTS accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

a.      It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favors or benefits.

b.      It is not made with the suggestion that a return favor is expected.

c.      It is in compliance with local law.

d.      It is given in the name of the company, not in an individual’s name.

e.      It does not include cash or a cash equivalent (e.g. a voucher or gift certificate) except for red packet tradition in token amount during the relative festive season from any party having business dealings with GTS.

f.      It is appropriate for the circumstances (e.g. giving small gifts around festive or ceremonial or as a small thank you to a company for helping with a large project upon completion).

g.      It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.

h.      It is given/received openly, not secretly.

i.      It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.

j.      It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s director.

k.      Where it is inappropriate to decline the offer of a gift (i.e. when meeting with the giver who may take offence), the gift may be accepted.

l.      Recognizes that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

As good practice, gifts given and received should always be disclosed and recorded in the Gifts Register.

The intention behind a gift being given/received should always be considered. If there is any uncertainty, the gift must be refused.

a.     Prohibition of Donation / Contribution to Political Parties or Individual Politicians

Our Personnel and Business Partners must not make donation or funding of any kind to political parties or individual politicians or towards political campaigns or initiatives for or on behalf of GTS. Any request for political donation or contribution must be pre-approved by the Directors of GTS and no political contribution may be made unless GTS has received a satisfactory opinion from qualified local counsel as to its legality under applicable laws.

Our Personnel may participate in political activities in their individual capacity with their own money and at their own time but to make it clear that their individual political views and actions are personal and not reflective or representative of GTS. GTS will not reimburse any personal political contributions.

b.     Charitable or Educational Donations and Sponsorships

GTS will only provide charitable or educational donations and public welfare sponsorships if they are ethical and legal under applicable laws. All donation and sponsorship expenses must be approved in accordance with GTS’s standard operating procedures.

Our Personnel and Business Partners must never use donations or sponsorships to obtain business or advantage of any kind or unduly influence the outcome of a business decision or cause others to perceive it as such. The use of donations or sponsorships in this manner is strictly prohibited under this Policy.

5.3      Business Partners and Their Conduct

a.     Our Personnel must carry out proper due diligence process and comply with all applicable GTS’s standard operating procedures before on-boarding any Business Partners. This include informing them of GTS’s Anti-Bribery and Anti-Corruption Policy and with effect from the date of this Policy, all Business Partners must submit an Anti-Corruption Declaration or confirmation in similar terms prior to on-boarding as GTS’s service provider.

b.     Our Personnel must monitor our Business Partners’ performance from time to time to be in compliance with this Policy, and where breach or suspected breach arises, immediate action must be taken. Failure to comply with this Policy by our Business Partners may lead to immediate termination of contract and claim for damages.

c.     In addition to all applicable anti-bribery and anti-corruption laws to which it may be subjected to, GTS expects our Business Partners to comply with this Policy in relation to all dealings by them for, on behalf of or involving GTS. Our Business Partners must also refrain and procure its affiliates to refrain from taking any action that would result in a violation of any applicable anti-bribery and anti-corruption laws and this Policy.

d.     Unless evidence suggests otherwise, all our Business Partners are independent contractors. They are not agent of, or representative of GTS and they are not entitled or must not hold themselves out to have the authority to bind GTS for any purpose.

5.4      Dealings with Governments and Public Officials

a.     Our Personnel and Business Partners must comply with all applicable laws, conduct themselves with integrity and apply the highest ethical standards whenever they deal or otherwise engage with governments, government agencies, regulatory bodies, statutory bodies (whether local or foreign) and any of its officials.

b.     Our Personnel or Business Partners must not directly or indirectly exert, or attempt to exert, any improper or illegal influence on public officials.

c.     If any information is required by any government, government agencies, regulatory bodies, statutory bodies (whether local or foreign), our Personnel must always consult their immediate supervisor before responding to such requests and ensure that all information provided is in good faith, truthful and accurate.

d.     Any improper or secret payments or transfer of items of any value (including facilitation payments) to public officials is strictly prohibited. If our Personnel have any doubts on whether such payments constitute an improper, secret and/or facilitation payments, please refer to the Integrity Team.

e.     Any improper or secret payments or transfers of items of value through intermediaries, or a third party, with the knowledge that all or part of the payment will contribute directly or indirectly as an improper, secret or facilitation payments to a public official is also strictly prohibited.

6. Conflicts of Interest

6.1   Conflicts of interest arise where there is personal interest that can be considered to have potential interference with objectivity in performing duties or exercising judgement for or on behalf of GTS. Our Personnel must avoid situations in which their personal interest would conflict with their duties and responsibilities. Our Personnel must not use their position, official working hours, GTS’s resources and assets, or information available to them for personal gain or to GTS’s disadvantage.

6.2   In situations where conflict of interest arises, our Personnel are required to immediately declare the matter to their immediate supervisor.

7. Responsibilities & Enforcement For Non-Compliance

7.1   Our Personnel must ensure to read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information given.

7.2   Our Personnel and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. It is required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

7.3   If our Personnel have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, they must notify the director.

7.4   If any of our Personnel breaches this policy, disciplinary action will be taken and could face dismissal for gross misconduct. GTS has the right to terminate a contractual relationship with particular Personnel if this anti-bribery policy is breached.

7.5   For Business Partners, non-compliance of this Policy may lead to termination of contract and claim for damages.

8. Raise a Concern

 8.1        Raise a concern

If our Personnel suspect that there is an instance of bribery or corrupt activities occurring in relation to GTS, our Personnel is encouraged to raise concerns at an early stage as possible. If our Personnel are uncertain about whether a certain action or behavior can be considered bribery or corruption, they should speak to the line manager, or the director.

GTS will familiarize all employees with its whistleblowing policy so employees can vocalize their concerns swiftly and confidentially.

8.2       Victim of bribery or corruption

Our Personnel must report to manager as soon as possible if they are offered a bribe by anyone, if our Personnel are asked to make one, if our Personnel suspect that they may be bribed or asked to make a bribe in the near future, or if our Personnel have reason to believe that they are a victim of another corrupt activity.

8.3       Protection

If our Personnel refuse to accept or offer a bribe or our Personnel report a concern relating to potential act(s) of bribery or corruption, GTS understands that they may feel worried about potential repercussions. GTS will support anyone who raises concerns in good faith under this policy, even if investigation finds that our Personnel were mistaken.

GTS will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because our Personnel reported a concern relating to potential act(s) of bribery or corruption.

Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavorable treatment in relation to the concern the individual raised.

If our Personnel have been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, our Personnel should inform the line manager or the director immediately.

9. Training and communication

 9.1       GTS will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that our Personnel will comply with this policy.

9.2        GTS’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.

9.3        GTS will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.

10. Record keeping

 10.1   GTS will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review.

11. Revisions

11.1   Any need for improvements will be applied as soon as possible. Our Personnel are encouraged to offer the feedback on this policy if there are any suggestions for how it may be improved. Feedback of this nature should be addressed to the director.

11.2   This policy does not form part of our Personnel’s contract of employment and GTS may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

Purpose

Our Human Rights Policy is an extension of the Company’s commitment to good workplace practices and include people in communities in our areas of operation.

Scope

This policy applies to all our employees regardless of employment agreement or rank, including suppliers and subcontractors acting on our behalf and we shall work towards implementing the policy proportionately and appropriately in our supply chain.

Policy Elements

Non-discrimination

We will not tolerate against discrimination in any form and our employees are provided with equal career opportunities regardless of race, religion, colour, language and gender.

Health and Safety

We seek to ensure that all employees including foreign workers, work in a safe and healthy workplace environment as well as reasonable conditions and that they are treated with dignity and respect. We comply with applicable health and safety laws, regulations, and requirements. We are dedicated to take every measure to aim for zero fatalities, long time injuries and illnesses.

Harassment

We strive to provide a safe and mutually respectful workplace environment that is free from any ats of physical, verbal, sexual or psychological harassment, bullying, abuse, or threats by either their fellow employees or managers.

Privacy or Data Protection

 We respect the privacy and confidentially of our employees’ personal information and treat all personal data with integrity.

Forced Labor, Child Labor and Human Trafficking

 We do not tolerate any form of forced labor, including bonded labor, slavery, and human trafficking. Children employment is prohibited. As we comply with the prevailing laws.

Working Hours, Benefits and Wages

We must adhere to the stricter of Applicable law, industry standards or practices relating to minimum wages, work hours, overtime, and benefits. We must be committed to continuously developing employee skills and capabilities, and to providing opportunities for career advancement.

Leave

We must ensure that all employees have the right to sick leave, and annual holiday, as well as congratulatory leave for employees who have to care for a new-born or newly adopted child as provided by national legislation and replacement leave for employees who work during weekends and public holiday. Employees who take such leave must not, as a result, face dismissal or threat of dismissal.

Employee Contracts or Letters

All employees must be provided with a written, understandable, and legally binding employment contract or letter.

Policy Revision

This policy must be regularly reviewed in order to ensure its continued adequacy and relevance and may be amended at any time by the HR Manager.

Associated Policies or Procedures

·       Grievance Procedure

·       Bullying at Work Policy

·       Equal Opportunity Policy

·       Worker Welfare Policy

Purpose

This procedure is an assistance on how employees can raise a concern if they are aggrieved for whatever reason. We provide the solutions to resolve issues in the workplaces quickly and fairly to minimize any stress caused during the process.

Grievances, dissatisfaction, or complaints should, if possible, be resolved at the lower level, unless the employee concerned are not able to reach a settlement.

Procedures 

Statement of Intent

The purpose of this policy is to outline framework for Global Testing Services to responsibly manage bullying in the workplace and to ensure that bullying by or toward any GTS employees or members of public does not occur. GTS believes that all employees are entitled to work in an environment free from bullying.

Definition

Bulling is repeated, unreasonable behaviour directed toward a worker, or group of workers, that creates a risk to health and safety. It includes behaviour such as:

·        Verbal abuse

·        Intimidation and threats

·        Personal attacks

·        Misuse of power

·        Withholding information that is essential for someone to do their job

·        Excluding or isolating others

·        Interfering with someone’s personal property or work equipment

One-off behaviours can still present a risk to health and safety and will not be tolerated.

Bullying is taken seriously by this organisation and will be addressed. Disciplinary action  may be taken if this policy is breached.

Practice Guidelines

If you are being bullied, or see others being bullied at work, you can talk to your supervisor, or if this is not possible, talk the HR Manager, the contact people for this policy.

Reports of bullying will be followed up and in serious cases investigated quickly, objectively and fairly.

It is the company’s duty to:

·         Protect the dignity of all our employees

·         Review all policies and procedures so that they are consistent with the principles of justice, fairness and respect for employees and the organisation

·         Ensure that there are appropriate procedures, systems and campaigns in place to promote dignity at work

·         Educate all employees on their personal responsibility to behave in a way that respects the dignity of co-workers

·         Provide advice, information and support that protects the dignity of our employees

Roles and Responsibilities

It is the role of company management and supervisors to:

·         Provide induction and information to staff in this policy

·         Model positive and constructive behaviour in their treatment of workers

·         Monitor their workgroups and act if they become aware of any potential hazards

·         Address breaches of this policy

It is the role of employees to:

·         Treat fellow workers with dignity and respect

·         Comply with this Bullying policy

·         Where possible, report incidences of breaches of this policy to supervisors or management

Statement of Intent

This policy relates to all aspects of employment including recruitment and selection, academic promotion, job classification, staff development, supervision and interpersonal relationships.

At GTS, staff have a responsibility to contribute to the achievement of a productive, ethical, safe, and equitable work environment. This responsibility includes:

·     Staff

·     Subcontractors

·     Clients

·     Visitors

·     External people that GTS staff interact with as part of work

GTS’ policy is based on compliance with equal employment opportunity and anti-discrimination laws, as well as a strong commitment to ensuring that our workplace is a safe and pleasant place for all employees to work.

Our Commitment

It is the policy of Global Testing Services to provide equal opportunity for all persons, and to prevent the discrimination and harassment on the basis of:

·     Race, colour, descent, national or ethnic origin

·     sex

·     marital status

·     pregnancy, potential pregnancy

·     family responsibilities

·     disability

·     age

·     homosexuality

·     transgender status

·     political conviction, or

·     religious belief

GTS is committed to providing an environment of equal opportunity, respect and understanding. We believe this creates a more harmonious and productive workplace with stronger working relationships, resulting in improved provision of services and support. Equal Opportunity means we ensure our policies, procedures and actions reflect and value the social and cultural diversity within GTS through:

·     fair practices in the workplace

·     management decisions made without bias

·     recognition and respect for the social and cultural backgrounds of all staff and customers

·     the implementation of policies, procedures and strategies that support our commitments to respect, fairness, dignity, diversity and equity

·     provision of equal employment opportunity by making decisions concerning employees on the basis of merit and fairness only

·     skilled staff are retained through career development opportunities

·     implementation and continuation of a zero-tolerance policy for discrimination and harassment

·     all employees are treated fairly and equally

·     providing an effective procedure for complaints based on the principles of natural justice

·     treating all complaints in a sensitive, fair, timely and confidential manner

·     guarantee of protection from any victimisation or reprisal

·     encouraging the reporting of behaviour which breaches discrimination and harassment

Best Practice Guidelines

Equal opportunity at Global Testing Services refers to the right of all staff to work study and access services which are safe, equitable, free from discrimination or harassment, and in which every person is respected and treated fairly.

GTS’ commitment to equal opportunity encourages the acceptance and valuing of diversity within its staff.  GTS aims to assist members of under-represented equity groups overcome past or present discrimination and to provide a supportive and open organisation culture in which all staff are able to develop to their full potential.

Roles and Responsibilities

It is the role of company management and supervisors to:

·     Provide induction and information to staff in this policy

·     Model positive and constructive behaviour in their treatment of workers

·     Monitor their workgroups and act if they become aware of any potential hazards

·     Address breaches of this policy

·     Ensure Equal Opportunity policies and procedures are in accordance with relevant legislation

·     Educate staff at all levels on their Equal Employment Opportunity rights and responsibilities

·     Take immediate steps to address any harassment claims and ensuring they are resolved in a timely manner

·     Provide equal opportunity for staff to participate in career development and higher duties

It is the role of employees to:

·     Treat fellow workers with dignity and respect

·     Enforce a zero tolerance policy on discrimination, harassment or bullying

·     Ensure the working environment is free of sexist, racist or any other forms of stereotyping material, posters, screensavers, internet, email communications etc.

·     Promote happy positive and harmonious working relationships with others members of staff

·     Be aware of what to do if they feel harassed or if they witness harassment, discrimination or bullying

·     Be aware of their responsibilities under the law

Lodging a Complaint

Any member of staff who feels they have been discriminated against, or witnesses a fellow employee should immediately discuss their concerns with their line manager or supervisor. In the event that the individual does not feel comfortable disclosing concerns to their supervisor or line manager, they can direct their concerns to the Human Resources Manager.

Any breach of equal employment legislation by an employee will be considered to be a serious breach.

Policy Statement

Here at GTS we are committed to acting with integrity and morality in all of our business relationships. We are further dedicated to ensuring modern slavery does not exist in our company. GTS and all contractors working on behalf of GTS will be treated on the basis of the following fundamental principles.

Worker Welfare Principles

·     All workers shall be treated fairly, irrespective of their nationality, gender, ethnicity, social status, religion, family, sexual orientation, race, political affiliation or any other protected characteristics with regard to recruitment, employment and fair work practices

·     Forced, compulsory, bonded or indentured labour, human trafficking practices, or any other violations of human or labour rights in accordance with local, national or international standards will not be tolerated

·     Persons under the age of 18 shall not be employed

·     Wage payments are made consistent with applicable law

·     Workers have the freedom to exercise their legal rights, including raising a grievance, freedom of movement, resignation, freedom of association, or refusing to perform work that poses an unacceptable safety or health risk

·     The dignity of any worker is protected at all times. Inhumane treatment, abuse and humiliation in any form are not permitted

·     The use of misleading practices during recruitment of employees is not tolerated

·     Foreign employees will be provided a written contract in their own language if necessary, so they understand all terms and conditions of employment

·     A clean, secure, safe and healthy working environment is provided, including unrestricted access to water and toilet facilities at all times

·     All workers have freedom of movement outside normal working hours unless there are legitimate safety or security concerns that may threaten the health, safety and wellbeing of the worker

·     This policy will be communicated to all employees, managers, supervisors

·     Subcontractors of GTS shall bear full responsibility for fulfilling the requirements of this policy

Statement of Intent

Whoever we deal with, wherever we operate, we are committed to doing so lawfully, ethically and with integrity. It is the responsibility of each and every person to ensure that we fulfil this commitment in our day to day working lives. However, from time to time there may be situations where the right course of action is unclear, or there may be situations where you suspect or know that something improper, unethical or inappropriate is going on. We have both a moral and legal duty to take appropriate measures to identify such situations and attempt to remedy them.

Objectives

 ·       To ensure all employees feel supported in speaking up in confidence and reporting matters they suspect may involve anything improper, unethical or inappropriate

·       Encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organisation

·       Provide clear procedures for reporting

·       Manage all disclosures in a timely, consistent and professional manner

·       Provide assurance that all disclosures will be taken seriously, treated as confidential and managed without fear of retaliation.

When to Speak Up

Whistle blowing means a disclosure of information made by an employee or contractor, an external person or body where they reasonably believe that one or more of the following matters is happening, did happen, or may happen in the future;

·       Fraud

·       Dishonesty

·       Corruption

·       Damage to the environment

·       Danger to the health and safety of an individual

·       Failure to comply with a legal obligation

·       Unethical behaviour

·       Discrimination

·       Sexual harassment

·       Any other conduct that may cause financial or non-financial loss to GTS

·       Anything that may be in breach of GTS policies and procedures

·       A deliberate concealment of information of any of the above

This policy is not designed to deal with general employment grievances and complaints. GTS has other policies and procedures in place to deal with complaints. Discipline, grievance, harassment and equal opportunity policies also address standards of behaviour at work. These policies should be followed where appropriate.

Who to Contact

Any person who has reasonable grounds to suspect that reportable conduct has occurred and is apprehensive about raising his/her concern because of the fear of possible adverse repercussions is encouraged to report that suspicion to any of the following people:

·       Your department manager

·       Your Admin Manager contact

·       Your OHS contact

If you feel uncomfortable approaching any of these people, you should approach the Company Director with your suspicions.

You can raise your concerns either by email, orally or in writing.

We understand that matters raised under this policy may involve highly confidential and sensitive information and that you may prefer to make an anonymous complaint. When this is the case we will endeavour to investigate the concern fully, although a thorough investigation may be impeded if we cannot obtain further information from you.

Protection

GTS recognises that maintaining appropriate confidentiality is important in ensuring potential whistleblowers are comfortable in coming forward with their concerns. No person coming forward under this policy shall be subject to any detriment for coming forward (within the control of GTS), regardless of whether the concern is substantiated or not. In the event that a person feels they are being victimized as a result of making a complaint under this policy they must inform the HR Manager straight away, and the immediate and appropriate action will be taken to protect the person from reprisal.

Investigation

GTS will respond to all reported conduct matters as quickly and as sensitively as possible in accordance with all relevant laws and regulations. The purpose of these investigations will be to:

·       Establish if a wrongdoing has occurred and to what extent

·       Minimise the risk of further wrongdoing (loss of assets, financial loss, damage to reputation)

·       Protect all sources of evidence

The investigating officer must ensure all documentation and information relating to the complaint is kept secure and confidential.

Any person found to be involved in any wrong doing will be subject to investigation using our Disciplinary procedure. Where it is believed that criminal activity has taken place, the matter may be reported to the police and appropriate legal action taken.

False Allegations

GTS is committed to the protection of genuine whistleblowers against reprisals. However, where it is shown that a person has knowingly made a false report, or not made a report in good faith, then that conduct itself will be considered a serious matter and may render the person concerned subject to disciplinary proceedings.