Whistleblowing Policy | Bricolage Philippines Inc.

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Whistleblowing Policy

MR D.I.Y. Philippines Whistleblowing Policy

I. Policy Statement

BRICOLAGE PHILIPPINES INC. (“MR. D.I.Y.”) and its Board of Directors/Stockholders are committed to the highest form of integrity and accountability in the course of its business. As such, it aspires to create culture of openness and responsibility in conducting its business. In line with this view, MR D.I.Y. undertakes to provide an avenue for all MR D.I.Y. Personnel, Third Parties and members of the public (“Whistleblowers”) to disclose any real or suspected corrupt incidents or misconduct involving MR. D.I.Y. This policy provides the necessary guideline to all Whistleblowers in making such disclosure.

Despite its commitment to conduct its business in the highest form of integrity, MR. D.I.Y. acknowledges that it is difficult to scrutinize and monitor each of its personnel’s conduct. As such, this initiative will help MR. D.I.Y. in monitoring and keeping track of illegal, unethical, or improper business conduct within MR. D.I.Y. which otherwise may not be easily detected through normal procedures.

II. Scope of Policy

This policy aims to facilitate all Whistleblowers in disclosing any misconduct through a proper channel. Misconduct shall include, but is not limited to the following:
- Fraud (embezzlement, forgery, theft and misappropriation, etc,)
- Bribery and corruption;
- Money laundering;
- Criminal breach of trust, abuse of power and position;
- Criminal offense;
- Improprieties and irregularities in accounting and financial reporting;
- Unauthorized disclosure or use of confidential information of MR. D.I.Y.;
- Sexual Harassment;
- Conflict of Interests;
- Gross negligence;
- Other unethical conduct (for example, miscarriage of justice, deliberate concealment of any malpractices).
- Knowingly directing or advising a person to commit any of the above wrongdoings.
- Non-compliance with laws, regulations, requirements of statutory bodies or public policies; and
- Non-compliance with MR. D.I.Y.’s policies and procedures or breach of internal control.

This policy does not invalidate nor take precedence over any other policy and Standard of Procedure of MR. D.I.Y but rather works in tandem with them.

All Whistleblowing reports have to be made in good faith with reasonable belief that the information and allegation is true and frivolously or maliciously or for personal gain.

III. Applicability of Policy

This policy applies to all MR. D.I.Y. Personnel, Third Parties, and members of the public (“Whistleblowers”).

All MR. D.I.Y. Personnel must be alert to situations and actions either theirs or others which may lead to misconduct or breach of any applicable laws or MR. D.I.Y.’s policies and procedures.

Any MR. D.I.Y. Personnel who received a whistleblowing complaint/ allegation from a Whistleblower, shall immediately forward such complaint/allegation to the Whistleblowing Unit for further action.

No one shall interfere with an ongoing investigation or otherwise attempt to influence the investigation team, Whistleblowing Unit, Panel of Domestic Inquiry, and/or the Whistleblower.

All Whistleblowers are encouraged and required to promptly report to the Whistleblowing Unit if there is a reasonable belief or suspicion that there has been any suspected and/or real violation of any applicable laws or relevant MR. D.I.Y. policies and procedures. The Whistleblowing Unit bears the responsibility to maintain and preserve all records of each procedural step from the receipt of a complaint/allegation to the decision made by the appointed Panel of Domestic Inquiry.

All Whistleblowers are expected to provide their utmost cooperation and assistance during an investigation.

IV. Procedures in Making a Disclosure

A whistleblower may lodge his/her complaint /allegation on bribery or corruption or any misconduct by writing to the Whistleblowing Unit or by filling out the Whistleblowing Form and email to the Whistleblowing Unit at [email protected]. Please refer to Appendix A for a copy of the Whistleblowing Form. Ethics Hotline number 0917-1610102 is also available to receive whistleblowing reports. Subsequently, the Whistleblower will be requested to fill out the Whistleblowing Form for details.

Upon receiving the written complaint/allegation or Whistleblowing Form, the Whistleblowing Unit will look into the nature of complaint and set up an Investigation Team for further actions and investigations. The investigation process will be managed with the highest standard of integrity, accuracy, and fairness. A proper investigation would determine the validity of the report received.

Investigation of the reported case/allegation shall commence only when sufficient evidence is submitted. The Whistleblowing Unit Lead shall follow up with the Whistleblower the evidence needed. If cannot be produced, the reported case/allegation will not be considered for investigation.

If any of the Whistleblowing Unit members is the subject of the complaint or suspected of being involved in corrupt activities and misconduct, he/she will be automatically abstained from attending the task.

If the complaint involves the Senior Management or Director of MR. D.I.Y. Philippines, the report shall be forwarded by the Whistleblowing Unit to the Chief Executive Officer (CEO). The CEO shall have the authority to make the final decision regarding the complaint.

If the complaint involves the Chief Executive Officer of MR. D.I.Y. Philippines, the report shall be forwarded by the Whistleblowing Unit to the Board of Directors/Stockholders. The Board of Directors/Stockholders shall then authorize a MR. D.I.Y. Director to be responsible for the investigation and recommendation to the Board of Directors/Stockholders. The Board of Directors/Stockholders shall have the authority to make the final decision regarding the complaint.

V. Protection Afforded to Whistleblower

All Whistleblowers (including MR. D.I.Y. Personnel, Third Parties and members of the public), provided that the complaint/allegation was made in good faith and with reasonable belief, will be afforded protection of confidentiality of identity to the extent possible.

Retaliation of any kind against any Whistleblower who makes a report in good faith and with reasonable belief and/or cooperates with any investigation will not be tolerated. Any MR D.I.Y. Personnel engaging in retaliatory conduct may be subjected to disciplinary action which may include termination.

However, the protection shall be revoked if the Whistleblower himself has participated in the misconduct complaint of.

MR D.I.Y. undertakes to not discharge, demote, suspend, threaten, harass or discriminate MR D.I.Y. Personnel who makes a report in good faith and with reasonable belief.

VI. Anonymous Complaint/ Allegation

Whistleblowers are encouraged to provide their identities and contact details to facilitate MR D.I.Y. for further clarification and/to obtain more information for purposes of investigation into the complaint/ allegation.

If a complaint/allegation is on anonymous basis, investigation of the complaint/allegation is limited to the extent of the contents of the complaint/allegation received by MR. D.I.Y.

VII. Secrecy/ Confidentiality

The Whistleblower, the Subject/Person Involved, the Whistleblowing Unit members, and everyone involved in the process shall:

- maintain complete confidentiality/secrecy of the matter.
- not discuss the matter in any informal/social gatherings/meetings
- discuss only to the extent or with the persons required for the purpose of completing the process and investigations.
- not keep the papers unattended anywhere at any time
- keep the electronic mail’s/files under password

If anyone is found not complying with the above, he/she shall be held liable for such disciplinary action as deemed fit.

VIII. Reporting

A quarterly report with the number of complaints received under the Policy and their outcome shall be reported to the Audit Committee by the Whistleblowing Unit Lead or representative.

Important: How to make a Whistleblowing Report

Reporting Mode	Contact Details
Letter	Bricolage Philippines Inc. (MR. D.I.Y. Philippines) 3A Xeland Building Guerilla St., Mayor Gil Fernando Avenue, Sto. Nino, Marikina City 1820 Philippines Attention: Whistleblowing Unit-Legal Dept.
Electronic Mail	[email protected]