Whistleblower Base, as an employee, board member, customer, supplier or other business partner, you can report serious matters anonymously or if you have reasonable suspicion of such matters. On this base, you can submit information about reprehensible matters or report actions that are unethical, illegal or in violation of internal policies. HR related matters cannot be reported in this system, but must instead be discussed with the immediate manager, director or HR. Your requests are treated confidentially and securely.

OUR POLICY

1. Objective: The target of this Whistleblowing Policy is to set the framework for the whistleblowing system of AlphaECC in addition to our usual reporting channels, can be used to raise any serious concerns, including any suspicion or knowledge of illegal, unethical or irregular conduct.

2. Who Can Raise Concerns?
Our employees, directors, customers, suppliers and other business associates.

3. How Are Concerns Raised? Access the whistleblower system on our website then the system will inform and instruct you about matters of importance to the assessment of the concern raised.

4. What Concerns Can Be Raised? You can use the system to raise all serious concerns. It could be suspicion or knowledge of any illegal, unethical or irregular conduct, including matters regarding

• Bribery, corruption,

• Abuse of funds, theft, deceit, embezzlement, fraud and other white-collar crimes;

• Personal data security violation,

• Serious environmental damage,

• Conflicts of interest,

• Sexual harassment or other gross harassment,

• Gross or repeated offences.

We will evaluate reports to understand what scopes they are referred to and in any application of the rules on protection of whistleblowers in Viet Nam in force from time to time.

Employees’ dissatisfaction like salary, management style, other contractual terms and conditions are not reported on this system, but addressed through the usual channels to your line manager, your trade union representative or Human resource.

Concerns must be raised in good faith (your understanding, concerns are wrong) or this systems will not work.

5. Handling Concerns Raised

Concerns will be evaluated whether the reporters and the concerns are within the whistleblower system. If not, the concern will be not be dealt with any further in this system and the reporters will be informed.

If initial screening shows that the reporters/concerns are within the system, these will be subject of investigation, the extent of which depends on the specific circumstances of the matter. The further investigation will generally be made by the management.

Feedback on the status of the concern will be released to reporters within three months, including the type of follow-up, if any.

6. Anonymity And Reporters’ Protection
You can always decide whether to raise your concern anonymously or with your personal contacts. In any case, we will generally process your personal data (if you have provided)

Reporters have options to decide whether he/she wants to be available for any further investigation by giving secure and anonymous mailbox that we can contact. We recommend you give contacts/email or it will be difficult for us to investigate more information from you.

When you want to reveal your identity, we will preserve your confidentiality as per Viet Nam Protection of Whistleblowers Act. Then, your identity will only, in principle, be disclosed if the you explicitly consents to this. Your identity can, however, also be disclosed to public authorities, such as the police or public prosecutor, if deemed necessary to respond to reported matters or for the purpose of ensuring the right to defense for the affected people. 

If your reports contain serious issues which is within our system, you may not face retaliation of any kind as a result of the concern raised.
 

IP address or the machine ID of the computer on which the concern is raised is not logged on in this system and no cookies are used in this system. If the reporters’ computers are owned by us or connected to our network, the IP address and/or the machine ID may be logged in the browser history and/or the log of our network that is made in our IT systems. You can avoid these by using computers not owned and/or connected on our network.

7. Notification To The Reporter (S) And Others
If the concern is about a named person, such person will be notified of the concern raised and its subject-matter to the extent required by law.
The notification will be made as quickly as possible and no later than 15 days after the concern has been raised. If there is a significant risk of the notification jeopardizing the investigation of the concern raised or the possibility of obtaining the necessary proof, it is possible, however, to postpone or not make the notification until the risk does no longer exist in compliance with the state laws.
 

Concerns must be raised in good faith (your understanding, concerns are wrong) or this systems will not work.

8. External Reporting Channels

The Government has external reporting channel, which supports employers’ duty to establish a whistleblowing system. Raising a concern through this external reporting channel is not conditioned by a preceding report to our system. However, we encourage you to raise your concern through our system so that we can quickly and immediately follow up on the matter concerned.

OUR PRIVACY POLICY

1. Purpose Of Processing Personal Data. In The Whistleblower System, the purpose of processing personal data in our whistleblower system is to uncover knowledge of serious matters, including suspicion or knowledge of any illegal, unethical or irregular conduct to prevent, limit and follow up on such matters in the entire organization. We control the personal data processed in our system. The data come from the group who may raise concerns through this system, i.e. the employees, customers, suppliers and other business partners.

2. Areas Of Personal Data Processed. A concern raised may contain the raiser’s personal data, general and sensitive personal data of affected persons and others’ The collected data could be name, position and any other data about the affected person(s), the concerns themselves and how they involve with the affected persons (s). A concern raised may include documents in the broad sense, including text, pictorial and video material. All personal data collected through the system will be treated as confidential to the maximum extent possible.

3. Processing Basis. It is necessary to process personal data in the whistleblower system to investigate and prevent serious matters in our company and in our system.

4. RIGHTS

4.1. Notification

If the concern raised affects one or several named persons, the person(s) in question will generally be notified about:

• The subject-matter of the concern raised;

• The outcome of the concern raised, including whether the concern is rejected as unfounded or made subject to further investigation;

• The law applicable to the processing of the relevant person's personal data and any other information that must be provided under data protection law;

• The persons with our company who have knowledge of the concern raised or will receive knowledge of the concern raised;

The notification will be made as quickly as possible and no later than 15 days after the above data have been obtained.

If there is a concrete risk of the notification jeopardising the investigation of the concern raised or the possibility of obtaining the necessary proof, it is possible, however, to postpone or not make the notification until the risk does no longer exist in compliance with the state laws.

If the concern contains data about other identifiable persons than the person that is the subject-matter of the concern, such persons will be notified as described above. This notification may not contain any identifiable data about the affected person.

4.2. Rights catalogue

When we has registered a reported person (perhaps reporters’ data and other person in the concern) that persons have a right to get into the personal data that are being processed about them. If the persons in question request a right of access, they will be informed of:
1.   Objective of the processing of the data;
2.   Type of personal data about the person in question that are being processed;
3.    The right of access only applies to personal data processed about the person himself/herself. A claim cannot be raised to receive access to data that only relate to other persons.
The right of access does not apply if it is found that the person's interest in receiving data about himself/herself should be superseded by important considerations for public or private interests.
The person also has a right to object to the processing of data and to request that data be corrected, restricted or erased in compliance with the data protection legislation in force from time to time.

5. Storing And Erasing Personal Data
Personal data processed in connection with concerns raised are kept as long as necessary in the interests of the investigation of the concern raised and the further course of events.
If the initial screening of the concern raised shows that the concern raised is not covered by our system or there is no proof of the concern raised, we will erase the concern raised and the personal data included in such concern as soon as possible and no later than three months after the conclusion of the initial screening.

6. Making available And Disclosing Personal Data
We processes the information internally received and is responsible for the initial screening of the received reports. 
We do not generally disclose personal data collected through the whistleblower system to third parties.
However, the following types of disclosure could take place on a case by case basis:
•    To an external advisor, for example an attorney or auditor for the purpose of a detailed investigation of the concern raised;
•    To relevant authorities, including the police and the prosecution service, in contemplation of any legal proceedings; and other disclosure required by law.

Reporters have options to decide whether he/she wants to be available for any further investigation by giving secure and anonymous mailbox that we can contact. We recommend you give contacts/email or it will be difficult for us to investigate more information from you.
 

When you want to reveal your identity, we will preserve your confidentiality as per Viet Nam Protection of Whistleblowers Act. Then, your identity will only, in principle, be disclosed if you explicitly consents to this. Your identity can, however, also be disclosed to public authorities, such as the police or public prosecutor, if deemed necessary to respond to reported matters or for the purpose of ensuring the right to defense for the affected people.

If your reports contain serious issues which is within our system, you may not face retaliation of any kind as a result of the concern raised. IP address or the machine ID of the computer on which the concern is raised is not logged on in this system and no cookies are used in this system. If the reporters’ computers are owned by us or connected to our network, the IP address and/or the machine ID may be logged in the browser history and/or the log of our network that is made in our IT systems. You can avoid these by using computers not owned and/or connected on our network.