Whistleblowing

policy

Integral to the business philosophy of Victorias Milling Company, Inc. (VMC) are integrity and accountability. As a matter of policy, all of VMC’s directors, managers, and employees are expected to act with integrity and honesty, and always in accordance with Philippine laws.

The Policy on Whistleblowing aims to assist individual employees to disclose information related to a suspected misconduct, malpractice, or irregularity through a confidential reporting channel. It is not designed to further personal disputes or question financial or business decisions taken by the Corporation.

What is a “whistleblower?”

A whistleblower is an employee who performs the following acts:

1. Discloses, threatens to disclose, or is about to disclose to a superior or to a public body, an activity, policy, or practice by the employer or a co-employee that the employee reasonably believes to be in violation of a law, rule, or regulation;

2. Provides information to, or testifies before, any investigating committee or public body conducting an investigation, hearing, or inquiry into any violation of law, rule, or regulation committed by the employer or a co-employee;

3. Discloses, threatens to disclose, or is about to disclose to a superior or to a public body, an activity, policy, or practice by the employer or a co-employee that the employee reasonably believes to be (i) in violation of VMC rules and regulations, and/or (ii) incompatible with the clear mandate of public policy concerning the public’s health, safety, or welfare, or the protection of the environment;

4. Assists the whistleblower in performing such acts; and,

5. Objects to, opposes, or refuses to participate in any activity, policy, or practice, which the employee reasonably believes to be (1) in violation of a law, rule, or regulation; (2) fraudulent or criminal; or (3) incompatible with a clear mandate of public policy concerning the public’s health, safety, or welfare, or the protection of the environment.

VMC’s actions

To encourage its employees to maintain the highest standards of integrity and accountability, VMC shall:

1. Encourage employees to report internally any suspected or actual violation of company policy, practice, law, or regulation by opening channels that will enable employees to report these in person or anonymously.

2. Conduct a prompt and thorough investigation on any alleged/reported violation and take appropriate corrective action.

3. Protect the whistleblower against retaliation, discrimination, harassment, or adverse personnel action for reporting in good faith a suspected or actual violation.

4. Not perform any act of retaliation, discrimination, harassment, or take any adverse personnel action against the whistleblower for reporting in good faith a suspected or actual violation.

On reporting violations

All reports will be confidential and the identity of the whistleblower will not be disclosed if the whistleblower so prefers, unless the whistleblower is required to stand as witness on record. VMC shall not be held accountable for maintaining anonymity in cases where the whistleblower has shared details of the report with others.

Anonymous reporting shall be allowed as long as such reports can be investigated appropriately and the information related to the report can be validated through reliable sources.