Ascend; Code of Conduct requires employees to observe high standards of business and personal ethics in conduct of their duties and responsibilities. As employees and Representatives of the company, they must practice honesty and integrity in fulfilling their responsibilities and comply with all applicable laws and regulations.
The purpose of the Whistleblower Policy is to enable a person who observes an unethical practice (whether or not a violation of law), to approach a Whistleblower Committee without necessarily informing their supervisors and without revealing their identity, if they choose to do so.
This policy governs reporting and investigation of allegations of suspected improper activities. Employees and others are encouraged to use guidance provided by this policy for reporting all allegations of suspected improper activities. In all instances, Ascend retains the prerogative to determine when circumstances warrant an investigation and, in conformity with this policy and applicable laws and regulations, the appropriate investigative process to be employed.
Any violation of the Guiding Principles of the Code of Conduct is a compliance violation
All employees are required to familiarize themselves with the Code of Conduct and abide by these principles. The Guiding Principles of the Code of Conduct are listed below
Any person may report allegations of suspected unethical activities. Knowledge or suspicion of unethical activities may originate from employees, contractors, clients, vendors, internal or external auditors, law enforcement/regulatory agencies or other third parties. Allegations of unethical activities may also be reported anonymously.
Reports of allegations of suspected unethical activities are encouraged to be made in writing so as to assure a clear understanding of the issues. Such reports should be factual rather than speculative and must contain as much specific information as possible to allow for proper assessment of the nature, extent and urgency of preliminary investigative procedures.
An unethical activity can be reported through any one of the following :
The following investigation process will be adhered to by Ascend in case the report is filed with the Whistleblower Committee or to any other Ascend employee.
Documentation and Reporting
Whistleblower
Investigation Participant
Investigation Subject
Whistleblower Committee
8. Whistleblower Protection
Ascend will use best efforts to protect whistleblowers against retaliation, as described below.
Ascend will keep the whistleblower's identity confidential, unless
Ascend prohibits retaliation against a whistleblower with the intent or effect of adversely affecting the terms or conditions of employment (including but not limited to, threats of physical harm, loss of job, punitive work assignments, or impact on salary). Whistleblowers who believe that they have been retaliated against may file a written complaint with the Whistleblower Committee. A proven complaint of retaliation shall result in a proper remedy for the person harmed and severe disciplinary action including termination of employment against the retaliating person. This protection from retaliation is not intended to prohibit managers or supervisors from taking action, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.
In the event that a complaint made in good faith is subsequently found to be untrue, no action would be initiated against the Whistleblower. However, action will be taken against Whistleblowers making baseless allegations.