Pan Asian Holdings Limited (“PAHL”) is committed to a high standard of compliance to local legislations and adopts zero tolerance on fraud and misconducts by employees. PAHL is committed to maintaining a fair and safe work environment. The board of directors together with its management strive to discharge their duties and responsibilities with the highest ethical and integrity.

In line with this commitment, this policy aims to provide an avenue for employees and external parties to raise concerns and report fraud, misconduct or complaints within PAHL. All whistleblowing complaints shall be dealt with independently, fairly and without prejudice.


The whistle blowing policy applies to PAHL directors, employees, stakeholders of the group as well as any external parties who may or may not have business relationships with PAHL.


The definition for a case to be reported under fraud or misconduct, means any:

  • Violation of laws and regulations;
  • Unethical practices;
  • Breach of internal controls, rules and regulations, standard operating procedures and any policies in place for corporate governance;
  • Unsafe work practices;
  • Abuse of authority;
  • Improper conduct and neglect in the discharge of duties;
  • Fraudulent activities that includes wrongful or criminal deception intended to result in financial or personal gain;
  • Conduct of oneself inconsistent with terms of an Employee’s employment; and
  • Any conduct that would cause PAHL to suffer adverse reputation.


(a)        We are committed to protecting and respecting the rights of any person who raises matters of concern under this policy.

(b)        We will not tolerate any reprisals, discrimination, harassment, intimidation or victimization of anyone raising a genuine concern or that person’s colleagues, employer (if a contractor) or relatives.

(c)        Reasonable steps will be taken so that any individual making a disclosure will retain their anonymity unless they agree otherwise. However, for an anonymous report to be investigated, it must contain sufficient evidence to form a reasonable basis for investigation. It must also be appreciated that following an investigation a statement by the person reporting the concern may be required to enable appropriate action to be taken.

(d)        We will ensure no one will be at risk of suffering some form of retribution as a result of raising a concern even if they are mistaken. We do not, however, extend this assurance to someone who maliciously raises a matter they know is untrue.

Making a report

All whistleblowing complaints are to be made directly to the Audit Committee via the email address - This email address is being protected from spambots. You need JavaScript enabled to view it.  

The whistle-blowing complaint shall include the following information:

  • Employee/whistleblower details such as name and contact details (if the whistleblowing report is not anonymous);
  • The specific concern;
  • The reason(s) for the concern;
  • The background and history of the concern, including relevant dates, time and place of the actions/transactions (where applicable and relevant);
  • If the concern has been raised with anyone else, if so, with whom.

Although employees/whistleblowers are not expected to prove beyond doubt the truth of an allegation, it will be necessary to demonstrate to the person contacted that there are sufficient grounds for real concerns.

The most appropriate person to contact will depend on whom the concern is about and the nature of the issues involved.

Investigation and Confidentiality

Employees/whistleblowers who have filed a whistleblowing report, will be informed within fourteen (14) days of a concern being raised, of who is handling the matter, how they can make contact with that person and if there is any further assistance required. We will give as much feedback as we can without any infringement on a duty of confidence owed by us to someone else in respect of whether further investigations will take place and if not, why not and indicating how the Company proposes to deal with the matter to be investigated.

The amount of contact between the persons considering the issues and the whistleblower will depend on the nature of the matters raised, the potential difficulties involved and the clarity of information provided. If necessary, the Company will seek further information from the whistleblower. Where any meeting is arranged (off-site if the whistleblower wishes) the whistleblower can be accompanied by a colleague and/or any other individual and have to notify the Company in advance.

We aim to commence investigations within twenty-eight (28) days of the complaint being lodged.

Employees’ identities will not be disclosed without prior consent. Where concerns cannot be resolved without revealing the identity of the employee raising the concern (e.g. if evidence is required in court), we will enter into a dialogue with the employee concerned as to whether and how we can proceed.

At the end of the investigation, the Audit Committee will report the findings to the Board of Directors, who will determine the action to be taken. In scenario where the whistleblowing report involves an AC member, the investigation process will be undertaken by the other AC members. The reported AC member will not be involved in the investigation process.

If the results of an investigation prove that the whistleblower to be submitting a complaint which he knows to be false or without any reasonable belief to be accurate and true of the complaint, management will consider to take appropriate actions against the whistleblower.

Once the matter is concluded, a report will be made to the person initiating the matter The report will explain the findings and actions taken to the fullest extent possible within commercial, legal and confidentiality constraints.