Whistle Blowing Reporting Channel

GTA Whistleblowing Committee (“BWC”) is established with the following primary objectives:

To review, investigate and resolve complaints of improper conduct of any member of the Board or any employee of the Company that is submitted to the BWC through the Company’s whistleblowing channel(s).
To develop the Company’s whistleblowing policy and procedures and to implement them together with the management of the Company.
To periodically assess the adequacy and effectiveness of the Company’s whistleblowing policy and procedures and to revise them as necessary.

Employees can report a Whistleblowing complaint if they are aware of any wrongdoings or improper conduct, which includes but is not limited to any unethical behaviour, malpractice, impropriety that includes:

(i) Financial malpractice or impropriety or fraud;
(ii) Serious non-professional or non-ethical behaviour;
(iii) Breach of confidentiality;
(iv) Misuse of Company’s funds or assets;
(v) Conflicts of interest;
(vi) Sexual harassment;
(vii) Criminal activity;
(viii) Attempts to conceal any of the above; and
(ix) Any other conduct which may cause loss to the Company, or otherwise be detrimental to the interests of its shareholders and the public

Acting in Good Faith

The WBC expect all parties to act in good faith and have reasonable grounds when reporting a Whistleblowing complaint. If allegations are proven to be malicious, parties responsible may be subject to appropriate action, where applicable.

Protection from Retaliation

Any party that retaliates against someone who has reported a wrongdoing in good faith may be subject to appropriate action, where applicable.

Whistleblowing Terms of Reference: [click to download pdf file]