Union Gas Holdings Limited adopts zero tolerance towards any fraud. SP is committed to maintaining an honest, fair and transparent working environment with the highest ethical and moral standards. It will do its best to deter and eliminate all possible fraud within the company and to conduct rigorous investigation of all such cases.

Per Union Gas Holdings Limited’s Whistleblower Policy and Procedures, all whistleblowing complaints shall be dealt with independently, fairly and expeditiously.

Definition of Misconduct

Misconduct means any:

  • violation of laws and regulations;
  • unethical or improper conduct;
  • breach of Union Gas Holdings Limited’s internal policies (including but not limited to the Union Gas Holdings Limited Code of Conduct), standard operating procedures, rules, guidelines, regulations and instructions that are in force or may be made or amended from time to time;
  • conduct in the discharge of the Employee’s work that jeopardises the safety of the Employees, the public or the environment;
  • behaviour inconsistent with the terms of an Employee’s employment;
  • abuse of authority;
  • neglect in the discharge of duties;
  • fraud;
  • any conduct that has adverse reputational and/or operational implications on Union Gas Holdings Limited; and/or
    suppression or concealment of any information relating to any of the above types of actions.

Making a Report

All whistleblowing complaints are to be made to Union Gas Holdings Limited’s Head of Internal Audit via one of the following communications channels:

A whistle-blowing complaint shall, to the extent possible, include the following information:

  • If an Employee, the Union Gas Holdings Limited division or department in which the Whistleblower works;
  • If a Non-Employee, where such person is employed or such person’s relationship to Union Gas Holdings Limited;
  • Date, time & place of the actions/ transactions;
  • Identity and particulars of the parties involved;
  • Evidence substantiating the allegations;
  • Any relevant information concerning the allegations; and
  • Contact details (to facilitate follow up queries).


Subject to applicable laws and regulations, Union Gas Holdings Limited will take reasonable steps to protect the confidentiality and anonymity of the Whistleblower consistent with the need to conduct an adequate review.

Anonymous Reporting

Union Gas Holdings Limited encourages Whistleblowers to identify themselves and provide their contact particulars. Union Gas Holdings Limited is committed to protect Whistleblowers under its Whistleblower Policy. Further clarifications are often needed and helpful in facilitating investigations into the whistleblowing complaints. The ability to investigate depends on the sufficiency and quality of the information provided by the Whistleblower.

Whistleblower Protection

Except for malicious whistleblowing, a Whistleblower who makes a complaint shall be protected against any reprisal.

Malicious Whistleblowing

If the results of an investigation show that the Whistleblower acted maliciously or did not act in good faith or submits a whistleblowing Complaint which he knows to be false, or without a reasonable belief in the truth and accuracy of the information, management will consider and take appropriate actions against the Whistleblower.