JapaneseWhistleblowingPolicy

1. Introduction

  1. AirTrunk is committed to ensuring the highest standards of conduct in all of its activities by:
    1. promoting and actively developing an enhanced culture of honesty, integrity, ethical behaviour;
    2. conducting our operations lawfully and responsibly;
    3. preventing and detecting suspected misconduct and illegal or unethical behaviour; and
    4. reviewing our operations and standards to ensure their continuous improvement.
  2. AirTrunk encourages the reporting of suspected misconduct within the company so that it can be dealt with appropriately.
  3. AirTrunk will protect and support anybody who raises a concern in accordance with this Policy against detrimental conduct.

2. Purpose

  1. This Policy is designed to establish a system for reporting and the proper handling of any complaints against any AirTrunk Japanese entities (each entity being a “Company“) including, but not limited to:
    1. consultations and reports in the event of illegal or improper acts;
    2. acts in violation of internal regulations such as the Work Rules and other regulations;
    3. acts that violate or are inconsistent with corporate ethics;
    4. acts that relate to improper conduct within the workplace such as bullying or harassment; and
    5. (acts that are suspected to be illegal or improper in relation to a Company’s business,

    (Collectively, “Wrongdoing“).

  2. It is also intended that this Policy will assist with the:
    1. early detection and correction of any Wrongdoing; and
    2. protection of Whistleblowers from retaliation for disclosures made in good faith.

3. Scope

  1. This Policy applies to:
    1. all officers and employees (including full-time employees, part-time employees, temporary employees, seconded employees, and retired employees) (collectively referred to as “Employees“) of the Company who make a report pursuant to this Policy; and
    2. anyone who has or had any type of business relationship with the Company including agents, volunteers, business partners, contractor, suppliers and their employees,

    (Collectively, “Whistleblowers“).

4. Types of Concerns to be Reported

  1. Employees have a responsibility to report any concerns they have about Wrongdoing occurring within the Company.
  2. Examples of the types of concerns that may be reported under this Policy are:
    1. Financial Reporting – examples include: falsification or destruction of business or financial records; misrepresentation or suppression of financial information; non-adherence to internal financial reporting policy/controls, and auditor independence concerns.
    2. Suspected Fraudulent Activity – examples include: theft, insider trading, market manipulation and corrupt practices including giving or receiving bribes or other improper benefits.
    3. Breaches of the Code, the Work Rules or other Policies and Laws and Regulations – examples include: conflicts of interest, illegal, deceptive or anti-competitive sales practices, manipulation of rates or price setting, other violations of governing laws and regulations including power or sexual harassment or other mistreatment of Employees or others and nonadherence to internal compliance policies.
    4. Retaliation against an Individual who reports a Wrongdoing – examples include:  statements, conduct or actions involving terminating, disciplining, demoting, suspending, harassing, intimidating, coercing or discriminating against an individual reporting a concern in good faith in accordance with this Policy.
  3. Whistleblowers should not feel constrained by these examples.  If a Whistleblower believes that they have become aware of a Wrongdoing it should be reported, even if it does not fall within the examples listed above.

5. Reporting Channels

  1. Whistleblowers may report their concerns internally in accordance with the procedures outlined below.  Whistleblower should choose the channel that is most appropriate given the nature of their concern.

6. How to Report

  1. Wrongdoings can be reported as follows:
    1. to the Japanese Whistleblowing Officer; Dai Tajima who is the Head of Legal (Japan) in person, by telephone or email to wbjapan@airtrunk.com. Only the Japanese Whistleblowing Office has access to this email address;
    2. to the Alternative Whistleblowing Officer, Jennifer Zheng who is AirTrunk’s Head of Risk and Sustainability by telephone or by email to wbalternate@airtrunk.com. Only the Alternative Whistleblowing Officer has access to this email address;
    3. where the Wrongdoing is of a workplace nature such as workplace bullying, the Wrongdoing should be reported to AirTrunk’s Head of People and Culture, Michelle Hannah by telephone or by email to michelle.hannah@airtrunk.com; or
  2. 6.2 Whistleblowers make also make a disclosure on a named basis or anonymously by utilising AirTrunk’s external whistleblowing channel. To access this portal, please go to https://www.whistleblowingservice.com.au/airtrunk/. To make an “Online” report please click on the ‘Make a Report’ button below. You will be redirected to the new page where you need to enter ‘AIR2021’ in the ‘Unique Key’ field. Click on ‘next’ and follow the prompt. You will then be asked for will then be asked for your “Client Reference Number”, which is 2vcfz2021.
  3. Whistleblowers must not make false reports, reports that slander others, or any other reports made with improper purposes.

Anonymous Reports

  1. The Policy encourages Whistleblowers to come forward in person wherever possible. However, anonymous reports will be accepted and investigated.
  2. When you may make a disclosure anonymously, please consider how the Japanese Whistleblowing Officer, or the Alternative Whistleblowing Officer, is to contact you moving forward.

Acknowledgement of Report

  1. Every reported incident will be acknowledged promptly by the Japanese Whistleblowing Officer, or the Alternative Whistleblowing Officer after receipt (factoring in weekends and public holidays), unless the Whistleblower has not left a method by which they may be reasonably contacted.

Review and Investigation of Reported Wrongdoings

  1. Upon receipt of a reported Wrongdoing, the Japanese Whistleblowing Officer, or the Alternative Whistleblowing Officer, will review and evaluate the severity of the Wrongdoing reported to determine whether an internal or external investigation is required.
  2. If an investigation is carried out, it shall be done in a fair and impartial manner. Any person who is involved in the content of Whistleblower’s report will be excluded from the oversight or participation in the investigation. Any person who is the subject of the Whistleblower report shall be given a fair opportunity to explain their views and rebut the content of the report. At no time will any such persons be advised of the Whistleblower’s identity.
  3. The Whistleblowers advised on the status of their report at the discretion of the Japanese Whistleblowing Officer or the Alternative Whistleblowing Officer as applicable. The Japanese Whistleblowing Officer or Alternative Whistleblowing Officer (as the case may be) might advise the Whistleblower of matters including:
    1. whether an investigation will be commenced/has been commenced;
    2. when any investigation has been concluded; and
    3. where appropriate, any steps that have been taken or will be taken to address the Wrongdoing.
  4. At no time are the Japanese Whistleblowing Officer or the Alternative Whistleblowing Officer be required to provide an update to the Whistleblower if it would compromise the investigation, or if it would comprise the position of other individuals involved in the reported Wrongdoing.

7. Confidentiality

  1. Unless compelled by judicial or other legal process to reveal the identity of the Whistleblower or having obtained the written consent of the Whistleblower, the Whistleblower shall remain confidential.
  2. No effort to ascertain the identity of any person or group who makes a report anonymously will be tolerated. Any Employee who improperly discloses the identity of the Whistleblower or attempts to ascertain the identity if a Whistleblower who made an anonymous report shall be subject to discipline under the Work Rules for violating Company policy.

8. Protection from Retaliation

  1. For the purpose of this Policy, Retaliation is an action that may harm or result in the detrimental treatment of a person who has raised issues or reported Wrongdoing in accordance with this Policy. Retaliation includes, but is not limited to:
    1. disciplinary measures such as dismissal, demotion, or reduction in payment;
    2. personnel measures such as unjustified reassignment of duties, isolation from work or assigning unnecessary tasks; and
    3. bullying or harassment.
  2. Any Retaliation against a Whistleblower will not be tolerated. The Company will take steps it deems reasonable and appropriate to protect Whistleblowers who raise issues or reports Wrongdoings in good faith.
  3. 8.3 If a Whistleblower or any person who cooperates in an investigation report that they have been subject to Retaliation, such claim shall be promptly investigated. If any Retaliation is confirmed, the Company shall take measures to end the Retaliation and provide any additional support to the Whistleblower that may be required.

9. Training

  1. The Company shall take reasonable steps, including through employee training and communication programs to educate all Employees about the procedures and protections contained in this Policy.

10. Procedural

Responsibility

  1. The department responsible for the Policy is AirTrunk Legal and the person in charge is the Chief Legal Officer.

Policy Review

  1. This Policy will be reviewed every two years.

Associated policies

  1. Global Whistleblowing Policy.
  2. Australian Whistleblowing Policy.
  3. Appropriate Workplace Behaviour Policy and Complaints Procedure.
  4. Anti-Bribery and Corruption Policy.
  5. Gifts and Entertainment Policy.
  6. Modern Slavery Policy.