As part of our Risk Management Framework, the Manager of Sabana REIT, has put in place a whistleblowing channel to help external stakeholders report, without fear of retaliation, discrimination or adverse consequences, on any wrongdoing that they may observe on the part of its officers and directors in their course of work, in particular, with respect to their obligations to the interests of the Trust.
Any wrongdoings involving:
All whistleblowing reports will be directed to the Chairman of the Audit Committee.
All information provided will be investigated, but consideration will be given to these factors:
Depending on the nature of the concern raised or information provided, the investigation may be conducted involving one or more of these persons or entities:
If, at the conclusion of an investigation, it is determined that a violation has occurred or the allegations are substantiated, remedial action commensurate with the severity of the offence will be taken.
Regardless of the significance of allegations or the outcome, all whistleblowing reports will be tabled and discussed at Audit Committee meetings.
Usually, within four weeks of receiving a whistleblowing report, the Chairman of the Audit Committee will write to the whistleblower:
It is essential for the Audit Committee to be given all critical information in order to be able to effectively investigate any wrongdoing. As such, the report should provide as much detail and be as specific as possible. It should contain details of the parties involved, dates or period of time, the type of wrongdoing, evidence substantiating the wrongdoing, and contact details.
Incomplete &/or anonymous reports are unlikely to be acted upon, as it is extremely difficult and often impossible to investigate if insufficient information is provided and the Audit Committee has no means to contact the whistle-blower to seek further information or gather additional facts, diminishing the likelihood of confirming the purported allegations.
All whistle-blowers are expected to:
Acting in good faith means without malicious intentions and in the better interest of the Trust. If allegations are proven to be malicious, appropriate actions, including legal action and blacklisting, may be taken.
The identity of the whistle-blowers will be kept confidential. However, their consent will be sought should there be a need to disclose their identity for investigation purposes. Please note the investigation may be impacted if they do not provide their consent.
Exceptional circumstances under which information provided by the whistle-blower could or would not be treated with strictest confidentiality include:
In the event the Audit Committee is faced with a circumstance not covered by the above, and where the whistle-blower’s identity is to be revealed, it will endeavor to discuss this with the whistleblower first.
The Audit Committee shall ensure that the whistle-blower is not victimised in any way, even if it becomes necessary for him/her to come forward to give evidence. Any employee, officer or director that retaliates against the whistle-blower who has filed a report in good faith may be subject to appropriate action, including legal action, where applicable.
The Manager reserves the right to modify the contents to maintain compliance with the applicable laws and regulations or accommodate organisational changes.
Appendix A: Download Whistle Blowing Form (here)