1. Purpose:

The purpose of this policy is to provide an avenue for employees and external stakeholders to raise concerns about any aspect of ROCS Group's operations, including suspected unethical behavior, fraud, and violations of company policies or laws, in a confidential and anonymous manner.

 

2. Scope:

This policy applies to all employees, contractors, suppliers, and clients of the ROCS Group.

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3. Policy Statement:

ROCS Group is committed to maintaining the highest standards of ethical, moral, and legal conduct. To facilitate this commitment, the Group provides an anonymous reporting mechanism to report concerns about unethical or

illegal conduct.

 

4. Anonymity and Confidentiality:

ROCS Group assures that all reports can be made anonymously and will be treated with utmost confidentiality. The identity of the whistleblower, if known or disclosed, will be kept confidential to the extent possible within the limitations of the law and the need to conduct a competent investigation.

 

5. Reporting Mechanism:

 

A. Reports can be made through the following channels:

• An online reporting form accessible through the company’s intranet and internet presence – www.rocsgrp.com/whistleblower

• A dedicated email address for whistleblower reports – whistleblower@rocsmail.com

 

B. The reports should provide as much detailed information as possible to facilitate effective investigation, including the nature of the issue, the individuals involved, dates, places, and any other relevant information.

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6. Protection from Retaliation:

ROCS Group strictly prohibits retaliation against anyone who, in good faith, reports a possible violation. Any form of retaliation will be subject to disciplinary action, up to and including termination of employment or contractual relationship.

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7. Investigation:

All reports will be promptly investigated by an impartial team or an independent third party, and appropriate corrective action will be taken if warranted by the investigation.

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8. Reporting to the Whistleblower:

While maintaining confidentiality and the integrity of the investigation, the whistleblower, if known, will be informed about the progress and outcome of the investigation, subject to legal constraints.

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9. Record Keeping:

Records of all reports, investigations, and outcomes will be maintained in accordance with the company's record retention policy and applicable law.

 

10. Policy Review and Amendments:

This policy will be reviewed periodically and may be amended at any time.

 

11. Communication:

This policy will be communicated to all employees and relevant stakeholders and will be accessible on the company’s intranet.

 

12. Administration:

The policy is administered by the Compliance and Legal Department operating within the CEO office of ROCS Group. They are responsible for providing guidance on the interpretation and application of this policy.

 

Conclusion:

ROCS Group encourages all employees and stakeholders to report in good faith any issues or concerns in accordance with this policy, as their contribution is invaluable in maintaining the integrity and ethical standards of the organization.

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