Your preferred comprehensive health insurance and well-being partner.
Your preferred comprehensive health insurance and well-being partner.
In this document:
2.1 Tangerine Group is committed to ethical and fair business conduct and does not tolerate any form of dishonesty, fraud, theft, corruption, malpractices or unethical behaviour in its operations. The Company requires Staff and all Parties that have business relationship with it to, at all times, act honestly and with integrity and to safeguard the Company's resources (tangible and intangible) for which they are responsible.
2.2 Tangerine Group has a zero tolerance to the commission or concealment of fraudulent, illegal, and unethical acts, including infraction of its business principles as well as other ethics related policies of the Company.
2.3 Therefore, all employees, consisting of permanent staff, contract staff, unconfirmed staff, agents, interns and Youth Corp Members, acting for and on behalf of the Company, are required to, without fear of reprisal, disclose actual, potential or suspected instances of malpractice to an internal source, as provided for within this Policy.
2.4 This disclosure requirement also extends to the Company's business associates and other external Stakeholders, such as contractors, consultants, suppliers, shareholders, clients, regulators, amongst others.
3.1 Whistle blowing is the act of disclosing or raising concerns about misconduct or other actions affecting the Company, or occurring within the Company, and which could endanger the Company and its employees or threaten its client's, shareholders, or the public.
Tangerine Group Code of Ethics and Conflict of Interests Manual
6.1 The Whistle blowing Policy provides for the reporting of all genuine concerns within any aspect of the Company's operations and involving employees or any party that has a business relationship with Tangerine Group. These concerns shall include:- Conduct that is against the Tangerine Group code of conduct, rules, procedures, and policies, or established standards of practice;
6.2 Conduct becomes reportable when it happens or when it is reasonably likely to occur.
6.3 The Company may be endangered if any of these conducts is left unchecked. Importantly, in determining whether to disclose a reportable incident, harm done to the Company is not solely measured in terms of financial loss or damage to a particular business, but harm is equally measured with regards to any damage done to the Company's integrity and reputation.
7.1 All information obtained from a Whistle blowing Report shall be considered confidential and would not be disclosed or discussed with other persons, except for the purpose of the investigation or where the Company has a legal or regulatory obligation to disclose.
7.2 Any individual, who reports, provides or obtains information as part of the investigation of a reported misconduct must not disclose or discuss the information or the investigation with other persons, internal or external.
7.3 Any breach of this Confidentiality would be treated in accordance with the Disciplinary Process as stipulated within the Tangerine Group Staff Manual.
An individual who observes, or becomes aware of a reportable misconduct, as defined within the Policy, has an obligation to report that conduct. Reports must be made in accordance with the requirements stipulated below.
8.1 Whistle blowing Channels
The channels and procedures for whistle blowing or raising complaints shall depend on whether the allegation, complaint or information is being made or disclosed by a staff member or by a party external to the Company.
Staff Members
Staff members are expected to whistle blow on transactions, operations and any other activities of the Company that involve fraud, corruption and misconduct, whether internal or external via the dedicated email address TangerineHealth.whistleblow@oalpconsulting.com call 02017001419
External Parties
Parties external to the Company, however, are required to bring allegations and complaints of corruption, fraud and any other misconduct in the execution of any business of the Company or project(s) related to the Company to the knowledge of the Company via the Whistle blowing link on the Company's website or send an email to TangerineHealth.whistleblow@oalpconsulting.com or call 02017001419
All communications made via the dedicated email address and the whistle blowing portal will be received by the Head of Internal Audit, Chief Compliance Officer and Managing Director/CEO.
8.2 Minimum Information Required for a Whistle blowing Report
1. Name of officer(s) involved
2. Nature of misconduct
3. Date of occurrence
4. Estimated value of loss to the Company (if any)
5. Specific evidence of occurrence of the misconduct
The Company wishes to assure the safety of whistle blowing, and therefore provides whistle blowers with the option of either confidential whistle blowing or anonymous whistle blowing.
9.1 Confidential Whistle blowing
A whistle blower is encouraged to reveal his or her identity when a report or disclosure is made using any of the channels mentioned above. This approach helps the investigation significantly, as the Whistle blower can be contacted to provide further details on the report, where necessary.
9.2 Anonymous Whistle blowing
However, a whistle blower may choose not to reveal his or her identity upon making a report. With the reporter's anonymity thus assured, the identity of the reporter cannot be ascertained by anyone. Should this approach be chosen, the Whistle blower must ensure that enough information is provided to enable a thorough investigation.
Whistle blowers should endeavour not to discuss the details of the reported misconduct with other persons, except as part of the investigation to ensure the protection of all parties involved and not to jeopardise the investigation process.
10.1 An employee making a Whistle blowing Report in good faith may do so without fear of retaliation or occupational prejudice. However, this protection is forfeited if it is found that the report was deliberately falsified or made with malicious intent.
10.2 Retaliation and occupational prejudice are in themselves misconducts, and when established, must be immediately escalated to the Audit and Compliance Units and would be handled through appropriate disciplinary proceedings as stipulated in the Tangerine Group Staff Manual.
11.1 Falsified and malicious allegations made through the Whistle blowing System would be considered misconduct and, when established, would result in disciplinary actions taken against the employee as stipulated within the Tangerine Group Staff Manual.
11.2 Reporting under this policy does not immunize or shield a whistle blower against action following from his or her intentional misconduct, which includes wilfully participating in the reported misconduct.
12.1 The Company is committed to investigating and addressing all cases of reported misconduct. Instances of suspected fraud and corrupt activities shall be investigated in accordance with the Tangerine Group Staff Manual.
12.2 All other instances of misconduct shall be assessed by the Internal Audit unit and referred to the appropriate Unit for investigation and necessary action. The Internal Audit unit shall follow-up to ensure that the report is properly investigated and adequately addressed.
12.3 All persons involved in the investigation of a reported suspicion in accordance with this policy will have access to all records, data, and information pertaining to the investigation.
12.4 Failure of any employee to assist in an investigation; or an intentional obstruction of the progress of an investigation by an employee would be considered a breach of contract and may result in disciplinary actions taken against the employee.
12.5 Interaction with law enforcement agencies would occur as it is deemed necessary and in accordance with the Tangerine Group Anti-Fraud Policy. As appropriate, relevant regulators will be informed of allegations and the subsequent outcome of investigations.
12.6 The whistle blower may seek follow-up information about the investigation of a report, escalated using the confidential whistle blowing option, or any consequent action taken by Tangerine Group.
13.1 As a first step, business-as-usual activities could be taken up with line managers or superiors. This however depends on the seriousness and sensitivity of the issues involved and who is thought to be involved in the malpractice. For example, if it is believed that Management is involved, the Internal Audit Team or Human Resources should be approached.
13.2 Concerns are better raised in writing but if the whistle blower does not feel comfortable to put his or her concern in writing, the Internal Auditor or any other designated officer as may be applicable may at his/her discretion decide to receive a complaint made by telephone or in person at a meeting. Written concerns should set out the background and history of the concern, giving names, dates and places (if known). In order to ensure the confidentiality of any expression of concern it is suggested that Whistle Blowers send their letter/written note in a sealed envelope addressed to the Internal Auditor and clearly marked as "Strictly Private and Confidential - To be opened by addressee only."
Reported misconducts involving an employee shall be escalated to the Head, Internal Audit and the employee's Line Manager
Reported misconducts involving a Departmental Head shall be escalated to the Head, Internal Audit and the MD/CEO.
Reported misconducts involving a member of Senior Management, with the exception of the Chief Compliance Officer, the Head Internal Audit or the MD/CEO, shall be escalated to the Head Internal Audit or the MD/CEO,
Reported misconducts involving the Chief Compliance Officer, the Head Internal Audit or the MD/CEO shall be escalated to the Chairperson, Board Audit and Compliance Committee.
The Internal Audit Unit has the responsibility of auditing the processes related to the reporting and investigation of all misconducts reported in accordance with the Whistle blowing Policy.
16.1 The Internal Audit Unit shall be responsible for monitoring and reviewing whistle blowing activities.
16.2 Reports on whistle blowing information shall be provided to Senior Management on a monthly basis and to the Board Audit and Compliance Committee on a quarterly basis.
In line with one of our core values; Integrity, we are committed to fostering a culture of honesty, transparency, and accountability. If you wish to report any suspected misconduct, unethical behaviour, fraud, or other whistleblowing concerns, kindly submit your report through any of the following channels:
Email Address
Telephone
All reports will be treated with the utmost confidentiality and handled in accordance with our Whistleblowing Policy.
Thank you.