Employee Column

Whistle Blowing Policy

All employees are encouraged to report genuine concerns about unethical behavior, malpractices including improprieties in financial reporting or internal control, illegal acts or failure to comply with regulatory requirements. The purpose of this Policy is to outline the channel and the process so that employees can do so without fear of reprisal when they act in good faith reporting such concerns.

Only genuine concerns should be reported under Whistle Blowing procedures. This report should be made in good faith with a reasonable belief that the information and any allegation in it are substantially true.

Procedures
  • In general, work-related issues should be discussed with immediate superior, and with the site General Manager, if required. If the concern remains unresolved, and/or if the employees feel that the concerns require the immediate attention of the Group management, she/he has the option of bringing the issue directly to the Group CEO.
  • Employees can report the issue by email, or by mail. Employees can log in to Pop Group Global website, and lodge their concerns under the Employees column ‘Letter to the CEO’. Employees are required to provide the company and department they worked, their genuine name, contact information and the facts of concern otherwise the concern will not be investigated.

Alternatively, the employees can mail their concerns in a letter marked strictly confidential to the CEO if they think it is appropriate.  Full contact information including the company and the department they worked, their genuine name and address, telephone number must be provided. The mailing address is as follows.

Pop Group Ltd.

3/F Shun Feng International Centre 

182 Queen’s Road East 

Hong Kong

Attn: The CEO

  • Genuine concerns raised to the CEO will be taken seriously and the confidentially of employees raising concerns will be protected.
  • Once we receive the employee concern, an acknowledgment of concern received will be replied to the employee. If the initial facts substantiate it as a valid concern, we will inform the employee that the concern will be investigated and followed up. However, if the concern is not valid, reason of the denial will be provided.
  • A log-book will be kept of all concerns received and their progress status.
  • The CEO or his designate will conduct an initial investigating meeting to discuss the concerns raised, and seek to establish the facts, and the further action to be taken. The employee raising the concern will be informed of the outcome of the investigation as soon as practicable. A written report of the conclusion shall be issued by the CEO or his designate.
  •  If the employee is not satisfied with the decision made by the CEO, he may appeal to the independent board committee, the Audit Committee which comprises of 3 independent non-executive directors and 1 non-executive director.
  • The Audit Committee shall review the case and designate personnel or hire outside professional body to investigate the case if necessary. A written reply shall be issued by the Chairman of the Audit Committee or his designate. If considered appropriate, the Chairman of the Audit Committee shall report the case to the Board for further action to be taken.
  • In case the concern is raised against the CEO, the employee can lodge it to the Audit Committee by logging in to the Pop Group Global website under Employees column ‘Letter to the Audit Committee’. Alternatively, if letter is to be sent, it should be marked strictly confidential and addressed to the Company Secretary, Audit Committee. In either case, employees are required to provide the company and department they worked, their genuine name, contact information and the facts of concern otherwise the concern will not be investigated. The mailing address is as follows.

Pop Group Ltd

3/F Shun Feng International Centre 

182 Queen’s Road East 

Hong Kong

Attn: The Company Secretary, Audit Committee

Reporting

The written report of the conclusion of all cases shall be filed as an official record by the Company Secretary in strict confidence.  The written report of the conclusion of all cases shall be made available upon request by any member of the Audit Committee.

Review

The Audit Committee will have the responsibility for monitoring the progress, producing and publishing results and undertaking periodic review. The Audit Committee will receive information periodically or at least twice a year on the numbers and types of cases arising from this policy prepared by the Company Secretary.