Whistle-Blowing Policy
Introduction
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This policy is intended to deter wrongdoing and to promote the conduct of all TMC’s business in accordance with high standards of integrity and good governance. TMC requires that all employees, officers and directors comply with all laws, rules and regulations applicable to themselves and the Company.
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If you are aware of the violation of any law, rule or regulation by TMC, whether by its employees, officers or directors, you can contact us at the email address below.
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Types of Improprieties
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Possible improprieties include but are not limited to the following:
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Financial malpractice or impropriety or fraud
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Failure to comply with a legal obligation or Statutes
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Dangers to Health & Safety or the environment
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Criminal activity
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Improper conduct or unethical behaviour
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Attempts to conceal any of these
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Safeguards
Protection
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This policy is designed to offer protection to those who disclose such concerns provided the disclosure is made:
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in good faith
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in the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety. It is important to note that no protection is offered to those who do not exercise this judgment. As in any case of malicious or wild allegations, legal actions may be taken by the person that is affected by the allegations.
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How to Report
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To enable TMC to effectively investigate your concerns, the following information should be provided, where possible:
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Name(s) of person(s) involved;
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Date, time and location of incident;
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Frequency of occurrence of the incident;
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Evidence;
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Any other information that may substantiate the concern;
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Whistle-blowers should report their concerns in good faith.
We encourage whistle-blowers to put their names to the allegations in case further information or clarification is required. To the extent feasible and permissible under the law, TMC shall make every effort not to reveal the identity of the whistle-blower.
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Reporting Channels
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All information should be sent to the following email address:
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Confidentiality
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The Company will treat all disclosures in a confidential and sensitive manner. The identity of the individual making the allegation shall be kept confidential as long as it does not hinder or frustrate any investigations. However, the investigation process may reveal the source of the information and the individual making the disclosures may need to provide a statement as part of the evidence required. This is particularly applicable if the issue is handled by the local authorities.
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Anonymous Allegations
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This policy encourages individuals to put their name to any disclosures they make. Concerns expressed anonymously are much less credible, even though they may be considered at the discretion of the Company.
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In exercising the discretion, the Company shall consider factors such as :
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Seriousness of the issues raised
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Credibility of the concern
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Likelihood of confirming the allegation from attributable sources
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Untrue Allegations
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If an individual makes an allegation in good faith and is confirmed by subsequent investigation, no action shall be taken against that individual. In making a disclosure, the individual should exercise due care to ensure the accuracy of the information. However, if an individual makes malicious or vexatious allegations and not on good faith, and persists to do so, disciplinary or legal action may be taken against that individual.
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