SP Group adopts zero tolerance towards any fraud. SP is committed to maintaining an honest, fair and transparent working environment with the highest ethical and moral standards. It will do its best to deter and eliminate all possible fraud within the company and to conduct rigorous investigation of all such cases.
Per SP Group’s Whistleblower Policy and Procedures, all whistleblowing complaints shall be dealt with independently, fairly and expeditiously.
Definition of Misconduct
Misconduct means any:
violation of laws and regulations;
unethical or improper conduct;
breach of SP Group’s internal policies (including but not limited to the SP Group Code of Conduct), standard operating procedures, rules, guidelines, regulations and instructions that are in force or may be made or amended from time to time;
conduct in the discharge of the Employee’s work that jeopardises the safety of the Employees, the public or the environment;
behaviour inconsistent with the terms of an Employee’s employment;
abuse of authority;
neglect in the discharge of duties;
any conduct that has adverse reputational and/or operational implications on SP Group; and/or
suppression or concealment of any information relating to any of the above types of actions.
Making a Report
All whistleblowing complaints are to be made to SP Group's Head of Internal Audit via one of the following communications channels:
A whistle-blowing complaint shall, to the extent possible, include the following information:
If an Employee, the SP Group division or department in which the Whistleblower works;
If a Non-Employee, where such person is employed or such person’s relationship to SP Group;
Date, time & place of the actions/ transactions;
Identity and particulars of the parties involved;
Evidence substantiating the allegations;
Any relevant information concerning the allegations; and
Contact details (to facilitate follow up queries).
Subject to applicable laws and regulations, SP Group will take reasonable steps to protect the confidentiality and anonymity of the Whistleblower consistent with the need to conduct an adequate review.
SP Group encourages Whistleblowers to identify themselves and provide their contact particulars. SP Group is committed to protect Whistleblowers under its Whistleblower Policy. Further clarifications are often needed and helpful in facilitating investigations into the whistleblowing complaints. The ability to investigate depends on the sufficiency and quality of the information provided by the Whistleblower.
Except for malicious whistleblowing, a Whistleblower who makes a complaint shall be protected against any reprisal.
If the results of an investigation show that the Whistleblower acted maliciously or did not act in good faith or submits a whistleblowing Complaint which he knows to be false, or without a reasonable belief in the truth and accuracy of the information, management will consider and take appropriate actions against the Whistleblower.