This Policy is not designed for enquiries, general feedback, complaints or grievances lodged by clients of Value Partners products and services. These should be reported via email email@example.com or firstname.lastname@example.org (for Value Partners Invest App).
Value Partners Group Limited and its subsidiaries (together the “VP Group” or “The Group”) are committed to conduct business in accordance with the highest standard of ethics and in full compliance with applicable rules and regulations. VP Group fosters an open environment in which employees and others can report instances of non-compliance without fear of recrimination.
This Policy shall be applied to VP Group, and its employees (full time and part time) and related third parties who deal with the VP Group (e.g. consultants, contractors, suppliers, agents and customers) (“Whistleblowers”).
- Examples of Issues
“Whistleblowing” refers to an act where an employee or related third party (“Whistleblower”) alerts the management to information which reasonably suggests there is misconduct, malpractice or irregularities within the Group.
The issues that constitute (or likely constitute) organizational malpractice or misconduct may include but not limited to:
• Criminal offences, breach of civil law and miscarriage of justice
• Malpractice, impropriety or fraud relating to internal controls, accounting, auditing and financial matters
• Failure to comply with any legal obligations, regulatory requirements, or VP Group’s policy
• Danger to health and safety or the environment
• Improper behavior or unethical behavior likely to prejudice the reputation or standing of VP Group (e.g. deception, theft, forgery, bribery or corruptions etc…)
• Attempts to conceal any of the above-mentioned issues
- Reporting Channels
Whistleblowers who become aware of any existing or potential misconduct, malpractice or irregularities within the Group shall report promptly via the following channel:
Email: email@example.com or
Mailing address: Attn: Value Partners Group Head of Group Internal Audit
43/F, The Center
99 Queen’s Road Central
Central, Hong Kong
The report should be marked “Strictly Private and Confidential” to ensure confidentiality. The complaint should include the exact nature, scope, and breadth of the accusation so that investigations can be conducted effectively. Disclosures without sufficient information and/or a method of contact may delay or prevent further investigation into the matter. All parties are encouraged to disclose your identity and contact details so that VP can contact you for further information.
- Handling of reports
Following such notification, an independent department e.g. Group Internal Audit Department will consult with appropriate persons on a need-to-know basis and initiate a preliminary investigation to determine if there are grounds for appropriate further action and decide how the investigation should proceed.
The recipient will write to the Whistleblower wherever reasonably practicable of the concern being received:
• acknowledging that the concern has been received within 7 working days;
• advising whether or not the matter is to be investigated further and if so what the nature of the investigation will be; and/or
• giving an estimate of time required for the investigation to provide a final response; informing the Whistleblower whether any initial enquiries have been made, and whether further investigations will take place, and if not, the reason of not taking.
The Whistleblower will be informed of the completion status of the investigation in due course.
VP Group will maintain records which contain all the information submitted with the complaint and a report detailing the investigation and the actions taken by the responsible parties as a result of the complaint. Where the report discloses a possible criminal offence, VP may refer the matter to the law enforcement agency.
Any allegation of victimization or retaliation which has been suffered as a result of a concern raised in good faith will be taken very seriously. Such an allegation will be promptly investigated and appropriate steps will be taken under VP Group’s disciplinary procedure. On the other hand, any report which, after investigation, proves to be deliberately false or malicious will activate VP Group’s disciplinary procedure.
- Confidentiality and Protection against retaliation
It is the policy of VP Group that staff or external parties should not suffer any form of discrimination, intimidation, reprisal, retaliation or adverse reaction organizationally as a consequence of reporting a concern about any of the above matters, even if they are mistaken.
VP Group will endeavor to protect the identity of the staff or external parties and their identities will not be divulged without their consent. However, there may be circumstances in which VP Group may be required or legally obliged to reveal their identities, for example, where an investigation leads to legal proceedings being initiated. If this is the case, VP Group will take all reasonable steps to ensure that the employee or external party suffer no detriment. Harassment or victimization of a genuine whistleblower will be treated as gross misconduct, which if proven, may result in dismissal.
The Whistleblower must keep all matters in relation to his/her disclosures entirely confidential and discussion about the matter should be limited to the Audit Committee / Group Compliance Department and the other functions listed above (if appropriate). Confidentiality additionally prohibits the staff from discussing or divulging any information in relation to such incident outside of VP Group, unless the staff is legally required to do so.
- Policy Review
The Policy shall be reviewed annually, where the Policy may be modified, to maintain compliance with applicable laws and regulations or accommodate organizational changes.