Last Updated: 20250303

1. PURPOSE

Kenfil Hong Kong Ltd. and their respective associated companies (collectively, the “Group”) are committed to establishing and maintaining best practices in corporate governance. All directors and employees of the Group and third parties who have business dealings with the Group are expected to conduct themselves with integrity, impartiality and honesty.

This policy is designed to encourage all directors and employees of the Group and third parties who have business dealings with the Group to raise serious concerns internally, without fear of reprisal or victimization, in a responsible and effective manner rather than overlooking a problem or blowing the whistle outside the Group’s reporting channels.

The purpose of this policy is to set out the Group’s policy on, and commitment to, whistleblowing and the protection of whistleblowers, and to provide details on how reports of improprieties can be made.

2. SCOPE

This policy applies to all directors and employees (full time and part time) of the Group and third parties who have business dealings with the Group (e.g. consultants and contractors, vendors and suppliers, customers and tenants, as well as agents) (“Whistleblowers”).

3. WHISTLEBLOWING AND IMPROPRIETIES

“Whistleblowing” refers to an act where the Whistleblowers report concerns about any suspected or actual improprieties related to the Group. It is every employee’s responsibility and in all interest of the Group to ensure that any inappropriate behaviour or organizational malpractice that compromise the interest of shareholders, investors, customers, directors, employees and the wider public does not occur.

“Impropriety(ies)” refers to any behaviour that is not in line with the Group’s principles and/or local jurisdictions where such behaviour could constitute a misconduct, malpractice or irregularity that should be reported.

Examples of improprieties include but are not confined to the following:

• Damaging the rights and interests of the Group;
• Breach of legal or regulatory requirements;
• Violation of Code of Conduct (applicable to staff) and/or Code of Conduct (applicable to relevant third parties), violation of the principle of integrity and breach of professional ethics;
• Endangerment of the health and safety of an individual;
• Any effort to mislead, deceive, manipulate or fraudulently influence any internal or external parties in connection with the preparation, examination, audit or review of any records of the Group including but not limited to financial statements, service contracts and personnel records; and
• Any use of the Group’s funds or property for any illegal, improper or unethical purpose.

4. REPORTING CHANNELS

The Group upholds the highest standard of business ethics and will take each report seriously. The Compliance Officer together with Head of Finance & Administration is responsible for the overall investigation. Whistleblowers should report their concerns about Improprieties in writing through the following channels:

By e-mail: [email protected]; or
By mail:
The Compliance Officer
Kenfil Hong Kong Ltd.
2/F., Centre Point,
181 Gloucester Road,
Wanchai, Hong Kong

If the complaint is against the Senior Management, the report should be sent to the Chairman’s Office.
While the Group does not expect the Whistleblower to have absolute proof or evidence of the improprieties reported, the report should show reasons for the concerns with full disclosure of any relevant details and supporting documentation.
Upon receipt of a formal written report from the Whistleblower, he/she will receive an acknowledgement of receipt as soon as practicable (if his/her contact details are known).

5. ANONYMOUS REPORTS

The Group respects that Whistleblowers may wish to file the report in confidence. However, an anonymous allegation will be more difficult for the Group to investigate effectively simply because the Group will not be able to obtain further information from the Whistleblower in order to make an adequate and proper assessment. Whistleblowers are encouraged to provide their identities and contact details so that they can be contacted for further information or evidence regarding the allegations.

6. INVESTIGATIONS

6.1. The Compliance Officer will assess every report received and decide if a full investigation is necessary. If an investigation is warranted, the Head of Finance & Admin will determine how the investigation should proceed, and assign designated staff to conduct the investigation. Experienced and skilled personnel from other relevant departments might be consulted if needed.
6.2. All whistleblowing cases and associated investigation works (if any) will be presented / submitted to the Investigation Panel (comprising unit heads from relevant corporate functions) for review to ensure that all complaints will be handled consistently, objectively and impartially.
6.3. For any substantiated case, the actions to be taken by the Group may include disciplinary action up to the termination of employment, cessation of contracts, as well as preventive actions and/or enhanced control measures in the future.
6.4. The format and the length of an investigation will vary depending upon the nature and particular circumstances of each complaint made. The matters raised may be investigated internally or referred to the relevant regulatory bodies such as the police, the securities regulator and any anti-corruption authority, as appropriate.

7. CONFIDENTIALITY AND ANTI-RETALIATION

The Whistleblower shall understand that any information (including but not limited to personal information and commercial secret of the Group or any third party) contained in the complaint and the information revealed by the investigation will be dealt with for the purpose of completion of the investigation and/or follow up actions and will be kept as corporate record of the Group. Such information and/or the work product derived from such information or the investigation thereof may be shared with any affiliate of the Group, professional adviser of the Group or any person in concern which may help the investigation of the compliant.
For the avoidance of doubt, the Group will keep the Whistleblower’s identity confidential and only disclose to relevant parties on a need-to-know basis and for the purpose of completion of the investigation and/or follow up actions. However, if the report leads to an investigation by regulators or authorities, it may become necessary for the Whistleblower to provide evidence or be interviewed by the relevant regulators or authorities to the extent allowed or required by the applicable law. The Whistleblower will be advised in advance if his/her identity may become apparent or needs to be disclosed to any external parties outside the Group. In order not to jeopardize the investigation, the Whistleblower is also required to keep confidential the fact that he/she has filed a report as well as the nature of concerns and the identities of those involved.
This policy is designed to offer protection to individuals who make complaints as Whistleblowers in good faith. Any Whistleblower raising genuine and appropriate concerns under this policy is assured of fair treatment, including where applicable, protection against unfair dismissal, victimization or unwarranted disciplinary action, even if the concerns turn out to be unsubstantiated.

8. FALSE REPORTS

While this policy is meant to protect the Whistleblowers from any unfair treatment as a result of their report, it strictly prohibits frivolous or slanderous complaints. All reports must be made in good faith. If it is found that the complaints have been raised frivolously, mischievously, maliciously or for personal gain, the Group reserves the right to take appropriate and commensurate actions against the Whistleblower to recover any loss or damage caused as a result of his/her report. In particular, if the Whistleblower is an employee, he/she may face disciplinary action, including and not limited to dismissal or cessation of contracts, where appropriate. It is important that the Whistleblowers should exercise due care to ensure the accuracy of the information.

9. RECORD RETENTION AND POLICY REVIEW

Records shall be kept for all reported Improprieties and in the event a reported Impropriety leads to an investigation, all relevant information relating to the case shall be retained, including details of corrective action taken, for a period as long as is considered necessary or such period as may be specified by any relevant legislation or authority. The Compliance Officer together with Head of Finance & Admin is also responsible for performing regular reviews and updates of this policy.