Whistleblowing Scheme

AMIT International Group and its affiliates (“AMIT”) have introduced a Whistleblowing regime in accordance with the Corporate Governance Policy, Group Values, Business Ethics and Conduct with honesty and integrity. The regime, which builds on existing requirements, aims to help:

• provide better legal protection for persons who report concerns regarding money laundering, fraud or any other financial crime.
• improve the Whistleblowing culture in the AMIT workplace and increase transparency around how AMIT will handle regulatory concerns.
• deter wrongdoing and promote better compliance and an ethical culture, by increasing awareness that there is a higher likelihood that wrongdoing will be reported.

What protections have been put in place?

The Regime has been established to strengthen the legal safeguard for individuals working at the Group at all levels and grades including, members of the executive management, senior managers, employees (comprising permanent, temporary and part-time employees), trainees, home workers, agency staff contractors, external consultants’ suppliers and vendors who report alleged misconduct within the entity or externally to their auditor or a law enforcement agency.

This protection will only apply where the disclosure of information relates to a reasonable suspicion that an officer or employee of AMIT or an Affiliate have or may have:

• contravened a provision of the Law, the Rules or any other policy administered by AMIT; or
• engaged in money laundering, fraud or any other financial crime, and where the disclosure is made in good faith.

What is Reasonable Suspicion?

This will depend on the particular circumstances and while “suspicion” is a relatively low threshold, the notion of reasonableness brings an objective test to the suspicion.

What is Good Faith?

This requires, for example, that something is done honestly rather than for a dishonest or malicious purpose. Under the regime, it is for the person making the disclosure to establish that these tests are met in order to receive protection.

Whistleblowing Reporting Mechanism

We have set up a specific AMIT Whistleblowing email address – [email protected] – and adhere to the AMIT Corp. Governance clause 15.5 & 15.6 Investigation of Reports which handled directly by the Audit and Risk Committee where a concern can be reported directly to the GMD.

Any information reported to AMIT is treated confidentially and access to that information would be limited to a small number of expert AMIT staff.

We would aim to respond to that report within 14 working days of receiving it. This would include an initial assessment of the report and potential requests for further information.

What next?

AMIT will be carefully monitoring compliance with this new regime and, in December 2024, will carry out a review of its implementation and whether the requirements have been effective in encouraging Whistleblowing and protecting Whistleblowers.