I.   Introduction 

This policy provides procedures for reporting questionable or improper accounting or auditing matters and violations and suspected violations of Republic Glass Holdings Corporation’s (“RGHC”) Code of Business Conduct and Ethics, and guidance in furtherance of RGHC Code.

 

Directors, officers or employees are expected: 

  • to observe high standards of business and personal ethics in the conduct of their duties and responsibilities;
  • to practice honesty and integrity in fulfilling their responsibilities and in compliance with all applicable laws and regulations;

II.   Reporting Responsibility

Each director, officer and employee has an obligation to report concerns about violations of RGHC’s Code of Business Conduct and Ethics, so that RGHC can address and correct inappropriate conducts and actions. 

 

III.   Reporting Procedure 

Each director, officer and employee has an obligation to report any concerns, questions, complaints or suspected violations to the Board of Directors through the Audit Committee.  Employee may contact any of the following resources to seek guidance and report his / her concerns:

  • His/her supervisor
  • His/her manager
  • Internal Auditor
  • Human Resources Officer
  • Compliance Officer
  • The Corporate Secretary of RGHC
  • Audit Committee 

IV.   Authority of Audit Committee

The Audit Committee is responsible for investigating and making appropriate recommendations to the Board of Directors with respect to all reported complaints and concerns. Investigation shall be conducted without regard to suspected violator’s length of service, position or relationship to the Company. 

 

IV.   No Retaliation

The director, officer or employee who reports an ethics violation, or suspected violation of law or suspected fraud or potential misconduct in good faith, is assured that RGHC will protect him/her  from any form of retaliation. Any retaliation or attempt to dissuade or obstruct an employee or others from providing such information or assisting in an investigation will be treated as a serious disciplinary offense that may require even dismissal. 

 

Any allegation that fails to be substantiated, or proves to have been made maliciously, recklessly or knowingly to be false will be viewed as a serious disciplinary offense that may even merit dismissal. 

 

V.   Confidentiality 

Reasonable effort will be exerted to maintain the confidentiality of the information received and those who report perceived misconduct in good faith. The investigation will not be disclosed or discussed other than to those with a legitimate right to know.  Disclosure of reports of concerns to persons or others not involved in the investigation will be treated as a serious disciplinary offense that may even merit dismissal.