Whistleblowing Regulation

Whistleblowing Regulation 2023 (Revision no.3)

1. Purposes
2. Definitions
3. Scope of Reports
4. Persons Entitled to File Reports
5. Investigation Participants and Accountabilities
6. Protection of Whistleblowers and Investigation Participants
7. Filing a Report
8. Procedures to be Undertaken by PTTEP
9.   Procedures to be Undertaken by Subsidiaries
10. Remedy
11. Enforcement of this Regulation
12. Penalty for Breach of this Regulation
13. Administration of this Regulation
14. Effective Date
15. Document Review
16. Appendix
 


1. Purposeclose | open
1.1  To set up a formal and effective reporting and whistleblowing procedure for PTTEP Group to meet international standards and best practices, enabling PTTEP Group to grow with prosperity, stability, sustainability and dignity;

1.2  To ensure that Directors, Employees, and any other person acting on behalf of PTTEP Group operate in a lawful, transparent, fair and accountable manner, along with remaining in compliance with the law as well as Good Corporate Governance Principles, Code of Business Ethics and other business regulations of PTTEP Group;

1.3  To enable people to report in good faith Misconduct or suspected Misconduct that may breach the law or violate the Principles, Code and other business regulations under Section 1.2, through channels established by PTTEP Group; and

1.4  To protect people who report actual or suspected Misconduct, and/or who collaborate with PTTEP Group in good faith from any form of retaliation as a result of those actions.
2. Definitionsclose | open
In this Regulation, the following words and phrases shall have the following meanings:

2.1   General Definition
  “Company” means PTT Exploration and Production Public Company Limited (PTTEP);
  “Subsidiary” means a company in which PTTEP holds, directly or indirectly, more than 50% of the shares;
  “PTTEP Group” means PTTEP and its subsidiaries;
  “Board of Directors” means the Board of Directors of PTTEP;
  “Director” means a director of PTTEP;
  “Employee” means all management, staff members, contractors, and other persons associated with PTTEP Group;
  “Supervisor” means any Executive-level or Management-level employee with whom an employee trusts and may file a report with;
  “Regulation” means rules, regulations, policies, guidelines, requirements, and the like that are deemed compulsory by PTTEP Group;
  “Report” means a report regarding Misconduct.
2.2 Definitions related to Misconduct
  “Misconduct” means any act which is illegal in the applicable governing jurisdiction(s) or which violates PTTEP Group Regulations, including the Good Corporate Governance Principles and Code of Business Ethics. For the purposes of this Regulation, Misconduct can be divided into 3 areas:
  2.2.1   Fraud means committing an act in order to procure, for himself/herself or another person, any advantage to which he/she is not entitled by law, which includes the following actions:
    (1)  Asset Misappropriation means possessing property belonging to another person, or of which the other person is a co-owner, and dishonestly converting such property for himself/herself or a third person.
    (2) Corruption means requesting, accepting, agreeing to accept, giving, offering, pledging, or promising to give assets or any kind of benefits to induce a public official (including a foreign government official and agent of any international organizations), agency, private body or officer of a private body, to wrongly exercise their powers. These powers include actions or inaction to facilitate, hasten or delay any act to benefit the PTTEP Group’s interest. Exceptions are cases where the giving or accepting of an asset or benefit is permitted by applicable laws, customs or norms.
      Corruption may come in many forms including political support, charitable contributions, sponsorship arrangements, facilitation payments, gifts, entertainment or hospitality, bribery, revolving door, conflict of interest and unwarranted allowances or expenses, as well as the improper use of third party agents and intermediaries.
    (3) Embezzlement means the act of deceiving a person with the assistance of falsehood or concealment of facts which should be revealed, dishonesty, and, by such deception, obtaining property from the person who has been deceived or a third person, or causing the person who has been deceived or a third person to execute, revoke, or destroy any document of right.
    (4) Statement Fraud or providing false information or misrepresenting facts such as financial statement fraud, the alternation of financial records by taking advantage of loopholes in accounting principles and various options for valuation. This includes the disclosure of accounting information to change information in financial statements for a wrongful purpose or distorting information for the benefit of an individual or group of people.
  2.2.2 Any act which does not comply with Human Resources Rules and Regulations of PTTEP Group.
  2.2.3 Any act which violates or does not comply with the law or PTTEP Group Regulations other than those described in Section 2.2.1 and Section 2.2.2.
       




3. Scope of Reportsclose | open

Directors, Employees, and any other person acting on behalf of PTTEP Group may be the Subject of a Report if he or she commits any act described in Section 2.2.1-2.2.3

The Company encourages whistleblowers to disclose their identity and to include as much information and clear evidence as possible concerning any Misconduct; for example

•  Name-surname and contact details of whistleblower
•  Name-surname of the subject of misconduct
•  Main complaint; factual information or description of behaviors or (mis)conduct that are applicable and important to the complaint under the scope of reports
•  Sufficient details, information or evidence of the reports

In case of an anonymous report, the Case Coordinator will assess whether there are reasonable grounds to proceed i.e. there is information indicating facts or clear evidence of the misconduct or fraud or there is a reason to believe in good faith that  misconduct or fraud has been committed. The following reports will not be considered:

3.1   reports which do not contain sufficient details or description to initiate an investigation.
3.2 reports that have already been received and are under a just consideration or fairly predicated by the Company’s Human Resources Division, the Company’s Internal Audit Division or any other authorized unit of PTTEP Group, unless additional significant details regarding the Report have been submitted.
3.3  reports which involve PTTEP Group’s policy or have been resolved by the Board of Directors or the Chief Executive Officer.
3.4  Reports which are under judgement or given final judgement.

 

4. Persons Entitled to File Reportsclose | open
Any person who is aware of or suspects in good faith that Directors, Employees or any other person acting on behalf of PTTEP Group has been involved in Misconduct under Section 2.2.1-2.2.3, whether or not he or she has personally suffered damage as a result of the Misconduct or any person who suffered any damages or affected by Reports/ Process of investigation may file a Report. PTTEP Group encourages whistleblowers to disclose their identity and/or provide sufficiently clear information and/or evidence concerning the actual or suspected Misconduct, and provide their contact information so as to enable effective communication with PTTEP Group.

In the event where there is clear evidence that whistleblowers have made a Report in bad faith, the Company shall undertake the following actions (as applicable) to restore the reputation of the Subject of a Report:

4.1   if the whistleblower is an Employee, he or she shall be subject to disciplinary action in accordance with the PTTEP Group’s Human Resources Rules and Regulations; or
4.2 if the whistleblower is a third party and damage has occurred to PTTEP Group as a result of such a Report, the Company may initiate action against the whistleblower.
5. Investigation Participants and Accountabilitiesclose | open

5.1  Report Receiver: Persons authorized to receive Reports are Directors, Supervisors and Case Coordinators, all of whom may receive Reports. After receiving a Report, these Directors and Supervisors shall remit the case to a Case Coordinator for further action.

5.2 Complain Screening Committee: Senior Vice President of Corporate Secretary and Assurance Division, Senior Vice President of Internal Audit Division, Senior Vice President of E&P Legal Division, and Senior Vice President of Human Resources Division or/and any authorized person designated by the Complaint Screening Committee to join the investigation may fulfil the role of the Complaint Screening Committee member to determine whether there is sufficient detail in a Report to initiate an investigation and to appoint investigators. However, The Committee member must not possess any conflict of interest with regard to a Report under investigation.

In a case where the Committee member has a conflict of interest or is a person who is the Subject of a Report, the Secretary to the Complaint Screening Committee shall report to Chief Executive Officer to appoint an authorized person in replacement being the committee member as appropriate.

5.3 Case Coordinator: Staff of the Corporate Governance Section of the Corporate Secretary and Assurance may fulfill the role of Case Coordinator and the Secretary to the Complaint Screening Committee. Upon receiving a Report, the Case Coordinator will preliminarily determine whether there is sufficient detail in a Report to initiate an investigation to the Complaint Screening Committee. Reports containing sufficient evidence will be referred to an Investigator who is designated by the Complaint Screening Committee. The Case Coordinator is also responsible for compiling evidence and making reports on progress related to the investigation as well as following up on investigation results and updating the status of reports, and, at the Case Coordinator’s discretion, granting the right to access report-related information. In addition, the Case Coordinator is obligated to ensure that the investigation is completed within the specified timeframe.

The Subsidiaries Case Coordinator is responsible for preliminarily determining whether there is sufficient detail in a Report of subsidiaries, compiling evidence and making reports on progress related to the investigation as well as following up on investigation results and updating the status of reports, and, at the Case Coordinator’s discretion, granting the right to access report-related information. In addition, the Subsidiaries Case Coordinator is obligated to ensure that the investigation of Subsidiaries is completed within the specified timeframe.

5.4 Subject of a Report: Directors, Employees or any other person acting on behalf of PTTEP Group who are the Subject of a Report of actual or suspected Misconduct under Section 2.2.1-2.2.3.

Where an Investigator subsequently considers that another individual has been involved in Misconduct, provided support for, or hired, requested or instructed the Subject of a Report to commit an act described in a Report, that person shall also be considered in the Investigation.

5.5 5.5 Investigation Participant: Directors, Employees and/or external third parties may be asked to cooperate with a Case Coordinator or Investigator by providing information that is or may be relevant to a Report.

5.6 Investigator: Investigators for reports concerning Employees’ s Misconduct under Section 2.2.1-2.2.3 shall be appointed as follows:

  5.6.1  the Internal Audit Division will be the focal point to investigate the reports regarding Misconduct which falls under Section 2.2.1 ;
  5.6.2 the Human Resources Division will investigate the reports related to Misconduct in accordance with the Human Resources Rules and Regulations which fall under Section 2.2.2;
  5.6.3 the Complaint Screening Committee will designate an investigator, may be the Internal Audit Division or the Human Resources Division or the Investigation Committee depending on the area of Misconduct, to investigate the reports concerning Misconduct under Section 2.2.3. When the appointment of the Investigation Committee is required, the case shall  proceed to Section 8.1.2.
  5.6.4 In case where reports regarding Misconduct which fall under Section 2.2.1-2.2.3 are particularly complex or will involve multiple units, the Chief Executive Officer shall appoint an Investigation Committee pursuant to Section 8.1.2.
  Whether or not an investigation is completed, any decision following the conclusion of an investigation shall be made in compliance with the Corporate Delegation of Authority and Signature (DAS).

5.7 In a case where the Case Coordinator is the Subject of a Report, the Chief Executive Officer will appoint an Investigation Committee as appropriate to approve the decision following the conclusion of an investigation.

5.8  In case where the Head of the PTTEP Internal Audit Division is the Subject of a Report, the PTTEP Audit Committee will appoint an Investigation Committee as appropriate to approve the decision following the conclusion of an investigation.

5.9 In a case where an Executive-level employee at the level of Department Head or Division Head is the Subject of a Report, the Chief Executive Officer will appoint an Investigation Committee as appropriate to approve the decision following the conclusion of an investigation.

In a case where an Executive-level employee at the level of Function Group Head or the Chief Executive Officer is the Subject of a Report, the Audit Committee (for the Misconduct under Section 2.2.1) or the Board of Directors (for the Misconduct under Section 2.2.2-2.2.3) will appoint an Investigation Committee as appropriate to approve the decision following the conclusion of an investigation and report to the Board of Directors for acknowledgement.

In a case where a Director is the Subject of a Report, the Board of Directors will appoint an Investigation Committee as appropriate to approve the decision following the conclusion of an investigation and report to the Board of Directors for acknowledgement.

An investigator following Section 5.6-5.9 must not possess any conflict of interest with regard to a Report under investigation.

5.10  Any decisions concerning the Employees, including disciplinary action, shall be made in compliance with the Corporate Delegation of Authority and Signature (DAS).

Decisions concerning the Head of the Internal Audit Division shall be considered for approval by the PTTEP Audit Committee.

Decisions concerning an Executive-level employee at the level of Department Head or Division Head shall be considered for approval by the Chief Executive Officer and report to the Corporate Governance and Sustainability Committee for acknowledgement. In a case where the Corporate Governance and Sustainability Committee has other opinions on the decision, the Chief Executive Officer will propose the decision to the Board of Directors for approval.

Decisions concerning an Executive-level employee at the level of Function Group Head or the Chief Executive Officer shall be considered for approval by the Board of Directors.

Any decision following the conclusion of an investigation, including disciplinary action, shall be made in compliance with the Human Resources Rules and Regulations.

5.11 Appointment of a Case Coordinator and an Investigator for a PTTEP subsidiary shall be made by the PTTEP Executive Vice President who is responsible for the supervision of the Subsidiary’s operations (or personnel authorized by that person, or personnel acting for the Executive Vice President), or the highest level of management of subsidiaries, or the highest level of management of the project in foreign countries, while the conflict of interest and checks and balances shall be taken into consideration.

In a case where the highest level of management of subsidiaries or the highest level of management of the project in foreign countries already appointed a Case Coordinator and an Investigator for the PTTEP subsidiary, they are required to report such appointment to the PTTEP Executive Vice President as provided in the first paragraph of 5.10 and the Corporate Governance Section of PTTEP.

5.12   Any decisions following the conclusion of an Subsidiary’s Investigation, including disciplinary action, shall be made in compliance with the DAS for International Assets or Corporate DAS as appropriate.
6. Protection of Whistleblowers and Investigation Participantsclose | open

PTTEP Group is committed to protecting people who report Misconduct in good faith under Section 4, or who are involved in an investigation under Section 5. PTTEP Group will not tolerate any retaliatory actions or threats of retaliatory action against anyone who has made a report of Misconduct in good faith. For example, personnel must not be disadvantaged or victimized by any of the following (actual or threatened) actions:  change of job position or workplace; work suspension; dismissal; or any other form of discrimination.

The identity of a whistleblower, report-related information, and the conduct of an Investigation shall be kept confidential by all participants involved. However, under some circumstances, PTTEP Group may disclose this information if the disclosure is required or authorized by law. Disciplinary action up to and including legal action may be taken against any person found to have intentionally disclosed confidential information.

7. Filing a Reportclose | open

People who detect or have reasonable grounds for suspecting Misconduct should submit a report via one of the following channels:

ึ7.1 a letter to Director or Chairman of the Audit Committee or Supervisor or the Corporate Governance Section, the Corporate Secretary
and Assurance Division

PTT Exploration and Production Public Company Limited
555/1 Energy Complex Building A, Floor 33
Vibhavadi Rangsit Road, Chatuchak, Bangkok 10900, Thailand;

7.2 an e-mail to Supervisor or the Corporate Governance Section, the Corporate Secretary and Assurance Division

at cghotline@pttep.com                                      

7.3 a report through the whistleblowing system on the PTTEP website at www.pttep.com                  

 

8. Procedure to be Undertaken by PTTEPclose | open

8.1  Report Investigation

  8.1.1  In a non-complicated case, i.e. a Report for which clear evidence has been submitted and/or which does not involve many units, a Case Coordinator will remit the case to an Investigator who is designated by the Complaint Screening Committee (see Section 5.6).
  8.1.2 In a complicated case, i.e. a Report which falls within the scope of a serious disciplinary action according to the Human Resources Rules and Regulations, a Report involving a large amount of evidence or complicated issues, or many units, an Investigator will remit the case to the Chief Executive Officer, who will appoint an Investigation Committee comprising a designated person from each of the following units: the Internal Audit Division, the Legal Division, and the Human Resources Division of PTTEP. The Chief Executive Officer may appoint an additional employee or a third party as an Investigation Committee member and designate the PTTEP Internal Audit Division or the PTTEP Human Resources Division being as a Secretary to the Investigation Committee and report the conclusion of an investigation to Supervisor of the Subject of a Report. An Investigation Committee member must not possess any conflict of interest with regard to a Report under investigation.
  8.1.3 In a case where the Case Coordinator is the Subject of a Report, those persons authorized to investigate into the cases under Sections 5.7 shall investigate a Report.
  8.1.4 In a case where the Head of the PTTEP Internal Audit Division, or an Executive-level employee at the level of Division Head, or Function Group Head, or the Chief Executive Officer, or a PTTEP Director is the Subject of a Report, those persons authorized to investigate the cases under Sections 5.8 and 5.9 shall investigate a Report.

8.2 Investigation Timeframes

  8.2.1 A Report Receiver shall remit the Report to a Case Coordinator within 3 business days from the day he or she receives the Report from a whistleblower.
  8.2.2 A Case Coordinator shall remit each Report to an Investigator within 7 business days from the day he or she receives the Report from a Report Receiver (or a whistleblower).
In case where it is not possible to comply with the specified timeframe, the Case Coordinator shall seek approval from the Chief Executive Officer for an extension of the investigation period for a period of 7 business days at a time.
  8.2.3 An authorized person shall appoint an Investigation Committee within 7 business days from the day the report is accepted in every case, except a case that an Executive-level employee at the level of Function Group Head, or the Chief Executive Officer, or a Director is the Subject of a Report, the Audit Committee or the Board of Directors will appoint an Investigation Committee as soon as possible.
  8.2.4 An Investigator under Section 5.6.1 or Section 5.6.2 or Section 5.6.3 (In case of no appointment of the Investigation Committee) shall examine each Report and submit a summary report on the final investigation results and recommended disciplinary actions (if any) to be imposed by an authorized person under Section 5.10 to a Case Coordinator within 30 business days from the day he or she receives the Report from the Case Coordinator. Any recommended disciplinary action made by the Head of the Internal Audit Division must be approved by the Head of the Human Resources Division and be in accordance with applicable Disciplinary Action standards of PTTEP.
In a case where it is not possible to comply with the specified timeframe, the Investigator shall seek approval from the Chief Executive Officer, for an extension of the investigation period for a period of 7 business days at a time.
  8.2.5 An Investigation Committee, composed in accordance with Section 5.6.3 (in case of the appointment of the Investigation Committee) Section 5.6.4, Section 5.7, Section 5.8, and Section 5.9, shall examine each Report and submit a summary report on the final investigation results and recommended disciplinary actions (if any) to be imposed by an authorized person under Section 5.10 to a Case Coordinator within 30 business days from the day the Investigation Committee becomes aware of the order appointing the Investigation Committee.
In a case where it is not possible to comply with the specified timeframe, the Investigator Committee shall seek approval from the Chief Executive Officer, the PTTEP Audit Committee, or the Board of Directors, as the case may be, for an extension of the investigation period for a period of 30 business days at a time.
  8.2.6 Failure to carry out the above procedures or requesting an extension of time in a timely manner shall be deemed as failure to comply with this Regulation by the relevant Case Coordinator or Investigator. In this event, the relevant Case Coordinator (or Investigator) shall report the reasons for the failure in writing to the person authorized to appoint the Investigator.

8.3 Reporting

  8.3.1 Case Coordinators shall summarize the results of an investigation for distribution as appropriate to the Whistleblower, Report Receiver, Subject of a Report, Investigation Participant, any other relevant persons such as Supervisor of the Subject of a Report, and government agencies as specified by laws.
  8.3.2 The investigator shall summarize the results of an investigation and any recommended disciplinary actions (if any) to be imposed by an authorized person under Section 5.10 for distribution to the Chief Executive Officer, the PTTEP Corporate Governance and Sustainability Committee, as well as to the PTTEP Audit Committee (in the case of Misconduct under Section 2.2.1).
  8.3.3 The Investigation Committee under Section 5.7, Section 5.8, and Section 5.9 shall summarize the results of an investigation and any recommended disciplinary action (if any) to be imposed by an authorized person under Section 5.10 for distribution to the Board of Directors.
  8.3.4 In a case where the Case Coordinator and/or Investigator considers during an initial examination that a Report may have significant impact on the reputation, business operations, and/or financial status of PTTEP Group, the Investigator shall immediately report the matter to the Case Coordinator to enable him or her to immediately report the matter to the Chief Executive Officer for further action. The level of damage may vary in different areas where PTTEP Group operates its business.
9. Procedures to be Undertaken by Subsidiariesclose | open
9.1  Filing a Report

  9.1.1  The whistleblower can submit a Report via the channels as specified in Section 7, however, the Subsidiaries may establish additional whistleblowing channels as appropriate with the agreement from the Corporate Governance Section of PTTEP.
The whistleblower can submit a Report to an Executive-level employee at the level of PTTEP Function Group Head who is the highest level of management of subsidiaries.
  9.1.2 The reports received through channels other than those provided in Section 7 are required to proceed according to the procedure specified in this regulation and be fully recorded in the central system.

9.2 Report Investigation

  9.2.1  Persons designated as Subsidiary’s Case Coordinators and Investigators by the PTTEP Executive Vice President or the highest level of management of subsidiaries or the highest level of management of the project in foreign countries under Section 5.11 shall examine Reports. In case of a complex case, a Subsidiary’s Investigator is to seek approval for the appointment of the Subsidiary’s Investigation Committee by the PTTEP Executive Vice President or the highest level of management of subsidiaries or the highest level of management of the project in foreign countries.
In a case where a Subsidiary’s Case Coordinators and/or Subsidiaries Investigators are the Subject of a Report, the highest level of management of subsidiaries or the highest level of management of the project in foreign countries shall appoint other persons in replacement and report such appointment to the PTTEP Executive Vice President pursuant to Section 5.11 and the Corporate Governance Section of PTTEP.
  9.2.2  In a case where the highest level of management of subsidiaries or the highest level of management of the project in foreign countries is the subject of a Report, a Subsidiary’s Case Coordinator shall submit a report to the PTTEP Case Coordinator to determine an appropriate action.
  9.2.3  In a case where the report concerns Misconduct under Section 2.2.1-2.2.3, the Subsidiary’s Case Coordinator shall report the case to the PTTEP Case Coordinator. This is to let the PTTEP Internal Audit Division consider whether there should be a PTTEP auditor taking part as investigation committee member or to appropriately follow up the investigation.

9.3  Investigation Timeframes

  9.3.1  The case handling process shall comply with the timeframe specified in Section 8.2.
  9.3.2 The time extension must obtain approval from an authorized person to appoint the Subsidiary’s Case Coordinator or the Subsidiary’s investigator, as the case may be.

9.4 Reporting

  9.4.1  The Subsidiary’s Case Coordinator shall report to the PTTEP Case Coordinator upon receiving a Report and summarize the results of an investigation for distribution as appropriate to the Whistleblower, Report Receiver, Subject of a Report, Investigation Participant, PTTEP Case Coordinator, and any other relevant persons such as Supervisor of the Subject of a Report.
  9.4.2  The Subsidiary’s Case Coordinator shall summarize the results of an investigation and recommended disciplinary actions (if any) to be imposed by an authorized person under Section 5.12. The summary reports shall be sent to the PTTEP Case Coordinators, who will make suggestions (if any), the highest level of management of subsidiaries or the highest level of management of the project in foreign countries, and to the PTTEP Executive Vice President under Section 5.11, who will make summarized reports on investigation results and the recommended disciplinary action (if any) to be imposed by an authorized person under Section 5.12. The PTTEP Executive Vice President under Section 5.11 shall send them to the Chief Executive Officer as well as to the PTTEP Corporate Governance and Sustainability Committee, as well as to the PTTEP Audit Committee (in the case of Misconduct under Section 2.2.1).
  9.4.3  In a case where a Subsidiary’s Case Coordinator and/or a Subsidiary’s Investigator appointed by the PTTEP Executive Vice President or the highest level of management of subsidiaries or the highest level of management of the project in foreign countries under Section 5.11 considers during the initial examination that a Report may have significant impact on the reputation, business operations, and/or financial status of PTTEP Group, the Investigator shall immediately report the matter to the Case Coordinator to enable him or her to immediately report the matter to the PTTEP Executive Vice President (or a person acting as Executive Vice President), or the highest level of management of subsidiaries or the highest level of management of the project in foreign countries under Section 5.11 for further action, and to PTTEP Case Coordinators for acknowledgement.


10. Remedyclose | open
If the complaint causes a detrimental impact on any person, the Chief Executive Officer will decide on an appropriate and fair method of mitigating that impact or remedy.
11. Enforcement of the Regulationsclose | open

This Regulation shall apply to PTTEP Group (except in case where the Company of PTTEP Group implemented the specific regulations or in case where this Regulation is contrary to the law of a country where a Subsidiary operates, the Subsidiary shall comply with the law).

12. Penalty for Breach of this Regulationclose | open
A person who, either intentionally or by negligence, fails to comply with these regulations or commits acts of harassment or threats, imposes disciplinary punishment upon, or inflicts unfair treatment upon an informant or any person involved in a Report because of the filing of the Report is considered to have committed a disciplinary offence  following the Human Resources Rules and Regulations, and shall be liable for damages occurring to the Company or any other person, including civil and criminal damages and any other liability otherwise provided by law.
13. Administration of this Regulationclose | open
13.1   This Regulation shall be administered by the Chief Executive Officer, who may issue relevant policies, guidelines, requirements, announcements, and orders as well as authorize other persons to have the power granted as necessary and appropriate.
13.2 This Regulation shall be construed literally according to its expressed provisions. In case of doubt, it shall be construed in accordance with the intention of this Regulation.
14. Document Reviewclose | open
This Regulation shall be reviewed in every 5 years or updated as necessary.
15. Effective Dateclose | open
This Regulation shall be effective from 29 November 2023. The Cases that are being considered under the previous regulation shall follow that regulation as long as it is not contrary to this Regulation.
16. Appendixclose | open

A.  Summary of whistleblowing management process



B.  Summary of whistleblowing management process for subsidiaries