info@nemasset.com
info@nemasset.com
NEM Asset Management Limited is committed to upholding ethical and fair business conduct and does not tolerate any form of dishonesty, fraud, theft, corruption, malpractices or unethical behavior in its operations. Therefore, the Company requires Staff and all Parties that have business relationship with it to, at all times, act honestly and with integrity and to safeguard the Company’s resources (tangible and intangible) for which they are responsible.
NEM Asset Management Limited has a zero tolerance to the perpetration or concealment of fraudulent, illegal and unethical acts, including infraction of its business principles as well as other ethics related policies of the Company.
Therefore, all employees, consisting of permanent staff, contract staff, unconfirmed staff, interns and Youth Corp Members, acting for and on behalf of the Company, are required to, without fear of reprisal, disclose actual, potential or suspected instances of malpractice to an internal source, as provided for within this whistle-blowing policy.
This disclosure requirement also extends to the Company’s business associates and other external Stakeholders, such as Contractors, Consultants, Suppliers, Shareholders, Clients, Regulators, amongst others.
Whistle-blowing is the act of disclosing or raising concerns about misconduct or other actions affecting the Company, or occurring within the Company, and which could endanger the going concern and reputation of the Company, adversely affect its employees or threaten its Clients, Shareholders or the public.
The act of whistle-blowing is an invaluable source of early warning, which alerts the Company to incidents that could be of negative consequences. It therefore serves as a useful tool in the identification and management of risk.
The purpose of the Whistle-blowing Policy is to ensure strict compliance with NEM Asset’s zero tolerance to fraudulent, illegal and unethical acts, thereby protecting the Company’s interest as well as that of its Clients and Shareholders. Accordingly, the Whistle-blowing Policy is intended to encourage and facilitate the disclosure of any form of misconduct to an internal authorised officer, via an approved means.
NEM Asset Management Limited requires that whistle-blowing disclosures are made internally and not to external sources. Where external whistle-blowing is done, it could be regarded as a malicious act, intended at hurting the Company.
NEM Asset Management Limited upholds a culture of openness, transparency and accountability; hence, the Company encourages an open and positive approach to whistle-blowing.
Rather than ignoring a problem, Employees, business associates and other stakeholders alike, are encouraged to disclose all reportable events that come to their notice, with the assurance that all information provided will be treated as confidential in nature and only shared with appropriate parties.
The Company shall investigate all allegations and issues of serious concern brought to its notice and shall take appropriate actions to address such concerns.
Consequently, Employees who do not comply with the provisions of the policy could be subject to appropriate disciplinary actions.
NEM Asset Management Company Limited Anti-Fraud Policy
The Whistle-blowing Policy provides for the reporting of all genuine concerns within any aspect of the Company’s operations and involving employees or any party that has a business relationship with NEM Asset Management Company Limited. These concerns shall include:
Conduct becomes reportable when it happens or when it is reasonably likely to occur.
The Company may be endangered if any of these conducts is left unchecked. Importantly, in determining whether to disclose a reportable incident, harm done to the Company is not solely measured in terms of financial loss or damage to a particular business, but harm is equally measured with regards to any damage done to the Company’s integrity and reputation.
All information obtained from a Whistle-blowing Report shall be considered Confidential and would not be disclosed or discussed with other persons, except for the purpose of the investigation or where the Company has a legal or regulatory obligation to disclose.
Any individual, who reports, provides or obtains information as part of the investigation of a reported misconduct must not disclose or discuss the information or the investigation with other persons, internal or external.
Any breach of this Confidentiality would be treated in accordance with the Disciplinary Process as stipulated by the Disciplinary committee.
Reporting
An individual who observes, or becomes aware of a reportable misconduct, as defined within the Policy, has an obligation to report that conduct. Reports must be made in accordance with the requirements stipulated below.
Where a reported misconduct is established as an Operational risk event, this must also be dealt with immediately
The Firm wishes to assure the safety of whistle-blowing, and therefore provides whistle-blowers with the option of either confidential whistle-blowing or anonymous whistle-blowing.
Whistle-blowers should endeavor not to discuss the details of the reported misconduct with other persons, except as part of the investigation so as to ensure protection of all parties involved and not to jeopardize the investigation process.
An employee making a Whistle-blowing Report in good faith may do so without fear of retaliation or occupational prejudice. However, this protection is forfeited if it is found that the report was deliberately falsified or made with malicious intent.
Retaliation and occupational prejudice are in themselves misconducts, and when established, must be immediately escalated to the Risk Management Unit and would be handled through appropriate disciplinary proceedings as stipulated.
Falsified and malicious allegations made through the Whistle-blowing System would be considered misconduct and when established, would result in disciplinary actions taken against the employee as stipulated.
Reporting under this policy does not immunize or shield a whistle-blower against action following from his or her intentional misconduct, which includes willfully participating in the reported misconduct.
The Company is committed to investigating and addressing all cases of reported misconduct.
Instances of suspected fraud and corrupt activities shall be investigated in accordance with the NEM Asset Management Company Ltd Anti-Fraud Policy. All other instances of misconduct shall be assessed by the Risk Management Unit and referred to the appropriate Unit for investigation and necessary action. The Risk Management Unit shall follow-up to ensure that the report is properly investigated and adequately addressed.
All persons involved in the investigation of a reported suspicion in accordance with this policy will have access to all records, data, and information pertaining to the investigation.
Failure of any employee to assist in an investigation or an intentional obstruction of the progress of an investigation by an employee would be considered a breach of contract and may result in disciplinary actions taken against the employee.
Interaction with law enforcement agencies would occur as it is deemed necessary and in accordance with the Nem Asset Management Company Ltd Anti-Fraud Policy. As appropriate, relevant Regulators would be informed of allegations and the subsequent outcome of investigations.
The whistle-blower may seek follow-up information about the investigation of a report, escalated using the confidential whistle-blowing option, or any consequent action taken by NEM Asset Management Company Ltd.
The Internal Audit Unit has the responsibility of auditing the processes related to the reporting and investigation of all misconducts reported in accordance with the Whistle-blowing Policy.
The Risk Management Unit shall be responsible for monitoring and reviewing whistle-blowing activities.
Reports on whistle-blowing information shall be provided to the Risk Management Committee or the Board, Enterprise Risk Management and Governance Committee on a quarterly basis.