Whistle-Blowing Policy

(Effective: 17 January 2018)

Villa Song Saigon Co., Ltd. (“VSS” or the “Company”) and its controlling shareholder Cornerstone Vietnam Limited (“CVL”) are fully committed to conducting business with integrity and consistent with the highest ethical standards, and in compliance with all applicable laws and regulations.

In an effort to strengthen corporate governance processes and practices, the Company has adopted a Whistle-Blowing Policy to provide a platform for you to raise any concerns you may have on possible wrongdoing involving Company officers and employees as well as consultants, suppliers, contractors, and/or any other parties with a business relationship with the Company.

It is the responsibility of all officers and employees of the Company to report any possible wrongdoing. All reports shall be treated by the Company as confidential.

The Company will not tolerate harassment or victimization of persons making a report and will take reasonable and appropriate action to protect you when you raise a concern in good faith.

Reporting Channels

You can report to us in any of the following ways:
Hotline:
Vietnam: +84 903441911

Email:
thuy.tathanh@villasong.com
compliance@villasong.com

Mail:
Director, Corporate Governance
Cornerstone Vietnam Limited
15 Scotts Road
#05-01/03 Thong Teck Building,
Singapore 228218

How and What to Report

Whistle-blowers may use any of the available communication channels mentioned in the above section to report their concerns.

To enable your concerns to be investigated effectively, the following information should be provided, where possible:

  • Name(s) of persons/companies involved;
  • Date, time and place of actions/transactions;
  • Value of any money or assets involved;
  • Any relevant information or document(s) that can assist the investigation.

Whistle-blowers should report their concerns in good faith and in the best interest of the Company and not with any bad intent.

We encourage whistle-blowers to put your name to your report in case further information or clarification is required. To the extent feasible and allowed under the law, the Company will make every effort not to reveal the identity of the whistle-blower.

Types of Wrongdoing

Possible wrongdoing to be reported include but are not limited to the following:

Fraud
This generally relates to the use of deception or misrepresentation to obtain an unjust advantage. It can also involve the theft or misappropriation of Company assets.

Corrupt Conduct
Corrupt conduct can take many forms including seeking, obtaining or offering secret commissions, theft, embezzlement, forgery, misuse of information, documents or materials acquired in the course of employment and dishonest performance of functions.

Questionable Accounting and Auditing Practices
Broadly, this refers to practices that do not comply with accounting or auditing standards, or are fraudulent or deceptive.

Adverse Behavior
This can involve illegal behaviour, including drug sale or use, gambling, violence or threatened violence, criminal damage against property and serious breaches against Company code of conduct.

How will the Company Respond

All whistle-blowing reports, other than reports involving any director or member of the senior management, shall be received by the Company Legal Representative with responsibility for corporate governance.

The Legal Representative of the Company shall conduct an initial review of the report received and the action taken by the Company will depend on the nature of the concern. All reviews shall be reported to the CVL Board of Directors for their attention and further action as necessary.

The matters raised may be:

  • investigated internally;
  • referred to external auditor;
  • referred to appropriate law enforcement agencies;
  • investigated by an independent inquiry.

Any report involving any director or member of senior management (having title of Legal Representative, General Manager and above) will be addressed directly by the CVL Board of Directors.

Implementation of the Policy

A copy of the Policy shall be made available on the Company website for transparency and ease of access by all employees and any parties who have business relationship with the Company.

All new employees shall be briefed on the Policy as part of their orientation program

Regular communications shall be made to stress to all employees the importance of this Policy as well as to maintain awareness of the Company’s continued commitment to this Policy.

The Company Legal Representative shall collate any feedback received and report to the CVL Board of Directors on a periodic basis.

The Company Legal Representative shall be responsible for maintaining, reviewing and updating this Policy. Any proposed revisions shall require the approval of the CVL Board of Directors.

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