Document Reference No.

Issue Date:
8/30/2023
IAD-PPPG-2023-001
Issue No. Revision No.
002 2

DOCUMENT TITLE: WHISTLE Blower Policy

1 POLICY STATEMENT

PhilCAT Employees are expected to adhere to the employee code of conduct and
demonstrate the highest professional standards in executing their job responsibilities.

PhilCAT encourages anyone to bring any ethical and legal violations that they are
aware of to the Management’s attention so that appropriate action can be taken
immediately to address the problem, and to minimize the PhilCAT’s exposure to any
damage that may occur when employees circumvent or overstep internal processes.

1.1 Objective

The policy reaffirms the PhilCAT commitment to good corporate governance. It also
serves as a guide for employees and anyone outside of the PhilCAT to raise any
concerns in a responsible manner. The policy intends to create an environment where
employees understand their responsibilities and Management can demonstrate their
accountability.

1.2 Scope

The policy applies to all employees in the PhilCAT organization.

1.3 Responsibility

All employees are responsible for ensuring compliance with this policy.

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Issue No. Revision No.
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DOCUMENT TITLE: WHISTLE Blower Policy

2 WHISTLEBLOWING

a. A whistleblower is someone who witnesses behavior by an employee that is

either contrary to the mission and core values of the organization or threatening
to the public interest, and who decides to highlight the issue to the relevant
internal authorities for the purpose of scrutiny and rectification.

b. This policy will enable the Management to take the necessary corrective action
when something is found to be amiss. It is not a means where a disgruntled
individual can abuse and seek to wreak revenge by giving away trade secrets or
holding an employee to ransom.

c. Areas For Whistle Blowing

Following are possible scenarios where whistleblowing may be raised. This may be
based on information, that the whistleblower reasonably believes and/or establishes
that inappropriate behavior has happened in the past, is currently happening, or is likely
to happen in the future:

a criminal act and/or violation of the code of conduct but not limited to

 the breach of a legal requirement;

 inappropriate behavior such as bribery; sexual
 a miscarriage of justice;
 a danger to the health or safety of any individual;
 Damage to the environment
 the deliberate cover-up of information that supports any of the above
matters.

3 Differences Between Blowing the Whistle and Making a Complaint

a. In practice, whistle-blowing occurs when an individual raises a concern about

danger or a legal requirement that affects others (e.g. customers, members of
the public, or the organization). The person blowing the whistle is usually not
directly or personally affected by the danger or illegality and hence does not
have a personal interest in the outcome of any investigation into the raised
concerns. As a result, the whistleblower who has no personal interest would
not be expected to prove the case, and he or she simply must raise the
concern so that others can address it. In the rare situation where the
whistleblower has a personal interest in the outcome of any investigation,

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IAD-PPPG-2023-001
Issue No. Revision No.
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DOCUMENT TITLE: WHISTLE Blower Policy

then he or she may be called upon to prove their case.

b. On the other hand, in a complaint, one is asserting that there is/are the
person(s) who have been poorly treated, for instance. The treatment could
involve a breach of the individual’s employment rights or a case of bullying,
intimidation, or harassment. The complainant is seeking redress or justice for
the hurt done. The complainant, therefore, has a vested interest in the
outcome of the complaint and, for this reason, is expected to be able to prove
their case.

4 Procedures

a. When an employee has witnessed an incident of inappropriate conduct, he or

she should raise the matter to his or her immediate supervisor promptly and
within a reasonable time. If he or she feels that this is not an appropriate
person, he or she should directly inform or write to the Human Resource
Manager or Internal Audit Manager. Meanwhile, he or she should be mindful
of the following:

 Think about the risks and outcomes before you act

 Remember you are a witness, not a complainant
 Think about what the result may be before you take any action
 Do not become a private investigator, especially where confidential
information is involved
 Do not forget there may be an innocent and/or good explanation
 Do not use this procedure to pursue a personal grievance

b. Employees can be assured that those who have raised any concerns in good
faith and reasonably believe them to be true, will be protected from possible
reprisals or victimization. As part of preserving the integrity and protecting
PhilCAT assets, every employee is encouraged to speak up about genuine
concerns about criminal activity, bribery, breach of a legal obligation (including
negligence, breach of contract, breach of security, breach of administrative
law), miscarriage of justice, danger to health and safety or the environment, and
the cover-up of any of these in the workplace. It applies whether or not the
information is confidential. PhilCAT views the victimization of whistleblowers
as a serious matter and will not hesitate to take disciplinary action.

c. When an individual who is not an employee has witnessed an incident of

inappropriate conduct, he or she should directly inform or write to the Human
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Resource Manager or Internal Audit Manager. The sanction will apply to those
if the information was divulged to other employees or people.

d. All reported incidents will be promptly and thoroughly investigated by the

Human Resource Department and Internal Audit Department the investigation
will be dealt with in confidence, with only relevant staff who need to know,
being informed.

e. In this regard, the PhilCAT has set up an Investigation Committee (consisting

of members from, HR, Executive Director, and Internal Audit to address and
handle matters arising from whistleblowing, as well as to implement follow-
through measures of rectification and prevention. In line with good corporate
governance practices, all cases of whistle-blowing will also be reported to and
reviewed by the Audit Committee (AC).

f. Upon closure of each whistle-blowing case, the Investigation Committee would

decide if it is in the interests of the PhilCAT and the whistleblower to make
public the results of the investigation to employees for their information
purposes. The consent of the whistleblower will also be taken into
consideration.

5 Reporting Mechanism

Individuals can report their concerns through the following channels:

 Human Resource Manager / Internal Audit Manager

 Hotline: +63270028160
 auditdepartment.philcat@gmail.com / humanresources.philcat@gmail.com

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