Whistle Blowing Policy

Central Finance Company PLC (CF) has a strong values based culture that encourages openness, integrity, and accountability, enabling our people to succeed together and deliver what matters.

The Whistle Blowing Policy is important in fostering a safe speak up culture and in helping to identify misconduct that may not be uncovered unless there is a safe and secure means for disclosing misconduct.

(a) To ensure that business is conducted in an ethical manner and in conformity with applicable laws and regulations.
(b) To enhance the culture of transparency, accountability and integrity.
(c) To provide avenues for employees to raise concerns.
(d) To make employees confident about raising concerns internally, by offering a reporting and investigation mechanism that is objective, confidential and independent, and protects employees from reprisal or disadvantage
(e) To explain how employees can report such concerns, the protections that will apply to them and how their concerns will be investigated
(f) To enable the management to be informed at an early stage about acts of fraud or illegal activities.

CF presumes that the employees will act in good faith and not make false or malicious allegations or accusations. The Company is committed to protect all employees who report concerns in good faith. If you believe that you have been penalized for doing so you should advise the management or either of the persons listed in Section 5 below. Retaliation for reporting concerns in good faith is an act of misconduct which may subject the person so retaliating to disciplinary procedures which may include termination. Similarly, an employee who knowingly or recklessly makes baseless allegations that are not in good faith may also be subject to disciplinary action, which may include termination.

This policy does not apply to complaints associated with unsatisfactory performance or evaluation reports, discriminatory work assignments, sexual harassment or any other personal grievances. These shall be referred to the Head of Human Resources Department and other mechanisms established for such grievances.

4.1 An employee may report instances of financial irregularities, fraud, misappropriation of funds, corruption, collusion, misconduct, deliberate violation of company procedures and codes of conduct, misrepresentation of information to the company and to its clients and/or any other fraudulent or any other activity which undermines the Company’s operations, values and ethics by superiors, subordinates, colleagues or any other employee.

4.2 Such reporting shall be in writing or by e-mail. In case of communication by e-mail, CF recommends that the subject of the e-mail be ‘CF Whistleblower’ for the purpose of ease of identification.

4.3 Employees are encouraged to report in writing as it would enable a clear understanding of the concerns raised.

4.4 CF recommends that the employee identifies himself/herself in the letter/email, however, if the employee prefers to remain anonymous such report also will be accepted

4.5 The Company will respect the privacy of all confidants and treat all submissions with discretion. This means that in most cases subject to the rule of law the identity of the whistleblower will be kept confidential. However, the circumstances of each situation will determine the level of confidentiality that can be maintained.

4.6 Any employee who has a concern should first raise such concerns to the HOD of such employee. If an employee feels that the concern relates to a matter which cannot be adequately addressed by such HOD he or she may choose to make direct contact with the persons whose names appear below.

Mr. Ronald George                                            Mr. Arjuna Gunaratne
GM Human Resources                                       Managing Director
Central Finance Co PLC                                      Central Finance Co PLC
No: 270, Vauxhall Street,                                    No 270 Vauxhall Street,
Colombo 2.                                                        Colombo 2.
Telephone: 0703-566899                                   Telephone: 0706739789
E-mail: ronaldg@cf.lk                                        E-mail: arjuna@cf.lk

Investigation processes will vary depending on the precise nature of the conduct being investigated. All investigations must be conducted in a manner that is fair, objective and affords natural justice to all people involved. A matter will not be investigated by someone who is implicated in the concern.

We provide updates through the system to people who raise concerns and where an investigation shows that wrongdoing has occurred, we are committed to changing our processes and taking action in relation to employees who has behaved incorrectly.

Our policy also covers the option to take disciplinary action against anyone who deliberately makes a false or malicious complaint. No action will be taken against an employee where the report was made in good faith but no wrongdoing was identified.

A report will be circulated semi-annually to the Board through the Audit Committee. This report will encompass the matters that have been reported along with the actions taken for each of these matters.

This Policy shall be reviewed once in every two years. However, it may be reviewed at an earlier date if necessitated by circumstances.

Communication of the policy to employees will occur through the CF Intranet.

Fraud : Any act or omission, including a misrepresentation, that knowingly and recklessly misleads, or attempts to mislead, a party to obtain financial or other benefit or obligation.
Corruption : The offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party.
Misconduct : Failure to observe the company’s codes of conduct, rules or standards of behavior.
Collusion : An arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
Illegal Activity : Actions or behaviors that are prohibited by governing laws and can result in legal consequences.