Whistle Blowing

 

OPEN-DOOR:

The open door policy is a voluntary process that allows the employee, client, third-party supplier or vendor to directly communicate with the controlling shareholder of Hi ACTA Limited (the “Company”), without fear of retaliation. To send an anonymous note, email musa@whatinvestorswant.com.

 

WHISTLE-BLOWING:

The CEO at Hi ACTA Limited is designated to take action he considers appropriate in order to investigate any actual or potential violations reported to him. If after such investigation, the CEO believes that a violation has occurred, he shall report the matter to the Executive Committee. If the Committee concurs that a violation has occurred, it will consider appropriate action.

 

RELATED-PARTY TRANSACTIONS":

This policy with respect to material Related Party Transactions at the Company is intended to ensure that related party transactions (“RPTs”) are conducted in a manner that will protect the Company and all its stakeholders from conflict of interest which may arise from such transactions, that the RPTs are entered into at, arms-length or at terms at least comparable to those available to unrelated third parties, and that these transactions shall be disclosed, reviewed, and approved in accordance with this Policy and consistent with the principles of transparency and fairness.

 

CONFLICT OF INTEREST:

The basic principle to be observed is that a director or any employee should not use their position to profit or gain some benefit or advantage for themselves or their related interests. They should avoid situations that may compromise their impartiality. If an actual or potential conflict of interest may arise on the part of a director or employee, they should fully and immediately disclose it and should not participate in the decision-making process.

 

A conflict of interest shall be considered material if the director’s personal or business interest is antagonistic to that of the corporation, or stands to acquire or gain financial advantage at the expense of the Company.

 

Each director or employee has a responsibility to the Company to avoid situations where a conflict of interest might occur. Employees are required to disclose to the Company any interest or benefits they have that may conflict with the business or interests of the Company.

 

Employees too, are expected to devote their full attention to the business interests of the Company. They are prohibited from engaging in any activity that interferes with the performance of their responsibilities to the Company or is otherwise in conflict with or prejudicial to the Company. Employees are prohibited from accepting simultaneous employment with another company, or with a supplier, customer, or competitor, and from taking part in any activity that enhances or supports a competitor’s position.

 

Willful withholding of information regarding a prohibited relationship may be subject to corrective action.

 

To send an anonymous note, email musa@whatinvestorswant.com

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