1. Any director, officer, consultant, employee, whether past or present, and any individual who provides supporting information shall be treated as a whistleblower and extended protection under this policy.
2. Any whistleblower who has believes in good faith that PHC or any person connected to a company has committed or omitted to do an act, and such act or omission violates a law, rule or regulation, or constitutes unethical conduct or fraudulent accounting or other practices should immediately report such information to the Chief Audit Executive (the “CAE”).
3. The CAE shall investigate or cause an investigation of the act or omission complained of and, if proven, shall recommend an appropriate penalty to Management, if the offender is an employee or consultant, or to the Board of Directors, if the offender is a director or officer.
4. The CAE and PHC shall, at all times, maintain the anonymity of the whistleblower and shall not reveal the whistleblower’s identity without the latter’s consent while such investigation is ongoing. Any director, officer, consultant or employee who reveals the identity of the whistleblower without the latter’s consent shall be subject to appropriate sanctions including dismissal.
5. Aside from maintaining the confidentiality of the identity of the whistleblowers, the PHC shall not tolerate retaliation or reprisal tactics against the whistleblower. Any director, officer, consultant or employee who engages in such retaliatory conduct against the whistleblower shall be subject to appropriate sanctions including dismissal.
6. If after investigation, it is found that the whistleblower intentionally made a false statement or report, the whistleblower shall be subject to appropriate sanctions including
dismissal.
Directors should ensure that their personal interests do not conflict with those of the Corporation. He should avoid situations that may compromise his impartiality. Any actual or potential conflict of interest should be fully and immediately disclosed and the director concerned should refrain from participating in the decision-making process.
Directors are committed to complying with all laws, rules and regulations including those related to insider information.
While the Corporation currently has no regular employees, in the future, it would give importance to their safety, health and welfare. The Corporation would provide a safe working environment with health and medical benefits and ensure that the employees’ working hours are reasonable. The Corporation would likewise provide training and development programs in the employees’ respective fields on an “as needed” basis.