Whistleblowing | Carter Industrial Company




This whistleblowing policy, aligned with the principles outlined in the Company's Code of Conduct, plays a crucial role in promoting transparency and accountability as part of our Corporate Compliance Program. Employees are encouraged to report any instances of misconduct involving the Company, its employees, consultants, contractors, or suppliers, without fear of retaliation or discrimination. This policy aims to foster a culture where concerns are addressed internally, ensuring the resolution of issues within the Company.



This policy applies to all individuals associated with Carter Industrial Company, including employees, managers, executive officers, and members of the board of directors. Furthermore, our whistleblowing system is open to external partners and stakeholders who wish to file a complaint, ensuring an inclusive approach to addressing potential misconduct.


The Whistleblowing System:

To facilitate the reporting of concerns, Carter Industrial Company has established a secure whistleblowing system. This system serves as a dedicated contact interface for receiving and managing reports on suspected misconduct. It is designed to protect the confidentiality of the reporting person's identity and any third parties mentioned in the report, preventing unauthorized access to this information.


Usage of Whistleblowing System:

The whistleblowing system is intended for reporting serious misconduct that directly affects the Company's vital interests or individuals' health and safety. Examples of such misconduct include financial crime, accounting irregularities, bribery, environmental risks or crimes, security vulnerabilities, serious forms of harassment or discrimination, violations of the Company's Supplier Code of Conduct, or violations of the Company's Code of Conduct.


The use of the whistleblowing system is justified when internal reporting channels may not be appropriate, especially if the reported person is part of the management or there is a risk of inadequate handling of the suspected misconduct.


Complementing Internal Reporting Channels:

The whistleblowing system complements the Company's existing internal information and standard reporting channels. It serves as an additional option for reporting concerns and is available on a voluntary basis.


Providing Comprehensive Information:

To facilitate a thorough investigation, it is important for the reporting person to include all relevant facts and carefully describe their claims. Additionally, attaching any pertinent documentation will assist in addressing the reported concern effectively.


Reporting Procedure:

  1. Any employee who wishes to report a concern regarding wrongdoing within the company may do so by contacting the site HR department. Alternatively, if a senior member of the site HR office is involved or if the concern involves the site HR department, the report may be escalated to the Group HQ HR department.
  2. Employees are encouraged to provide as much detail as possible when reporting a complaint, including specific incidents, individuals involved, and any supporting evidence.
  3. The reporting person should provide their name and contact details when reporting a complaint to facilitate subsequent investigation and communication. However, anonymous reports will also be accepted and will be treated with utmost confidentiality.


Handling of Reports:

  1. The HR department, whether at the site or Group HQ level, will promptly acknowledge the receipt of a reported matter and initiate an initial inquiry into the concern raised.
  2. If urgent action is required, it will be taken before any formal investigation takes place. The HR department will assess the reported matter and may conduct an investigation internally or involve other relevant departments or external parties, such as legal counsel or external auditors, as necessary.
  3. The HR department will ensure that all reports received are recorded in a manner that protects the identity of the reporting person. Only authorized staff members who are competent to receive or follow up on the reports will have access to this information.


Follow-up and Feedback:

  1. The HR department will conduct a diligent follow-up on each reported matter, keeping the reporting person informed of the progress and outcome of the investigation. The HR department will provide feedback within a reasonable timeframe, subject to legal constraints.
  2. The company will keep records of the reports received for the necessary duration to conduct follow-up actions and allow for a proper investigation. Reports will not be stored for a longer time than necessary and proportionate to the nature of the reported matter.


Protection against Retaliation:

  1. Carter Industrial Company strictly prohibits any form of retaliation, including attempts and threats, against an employee who has reported a genuine concern regarding wrongdoing.
  2. Any employee found to engage in retaliation may be subject to disciplinary action, up to and including termination of employment.


False and Malicious Allegations:

  1. The Company places great importance on honesty and integrity. While it is committed to investigating all complaints received, it expects employees to make sincere and truthful allegations.
  2. Deliberately making false or malicious allegations may result in disciplinary action.


Processing of Personal Data:

  1. Reports made through the standard reporting channels may contain personal data, including the identity of the reporting person and individuals involved in the alleged misconduct.
  2. The Company will only process relevant and accurate personal data necessary for the investigation. Sensitive personal data will not be processed unless required by law.
  3. The Company acts as the data controller for any personal data collected through the reporting channels. It is responsible for ensuring that personal data is processed in accordance with applicable data protection laws and regulations.
  4. Personal data collected will be processed by authorized individuals within the Company, including third-party IT service providers engaged by the Company. In some cases, personal data may be transferred to other departments within the organization, management, legal counsel, consultants, auditors, or law enforcement authorities.
  5. The Company will generally not disclose personal data to third parties unless required by law or as necessary for the investigation.


Legal Basis and Time of Storage:

  1. The collection and processing of personal data through the reporting channels are based on the legitimate interest of the Company in ensuring compliance with applicable laws and facilitating the reporting of suspected breaches. It is also based on the legal obligation to meet regulatory requirements.
  2. Personal data collected and processed will not be retained longer than necessary. Once investigations are concluded, complaints, reports, and information related to the misconduct will be deleted within a reasonable timeframe, except when the information is needed for ongoing investigations or legal purposes.


Your Rights:

Individuals whose personal data is collected through the reporting channels have the right to be informed about the processing of their data, access their personal data, rectify any inaccuracies, and request the erasure of their personal data under certain circumstances. If you would like to exercise your rights or have any questions or concerns regarding the processing of your personal data, please contact the HR department at your site or the Group HQ HR department.


June 30, 2023

Carter Industrial Company

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