Policy & Ethics

All complaints, regardless of channel, are logged in the Case Management System and assigned a unique reference number (report key) for tracking. The Ombudsperson conducts a preliminary assessment to confirm the complaint falls within scope.

If warranted, the Ethics Committee initiates a preliminary inquiry within 4–7 working days to evaluate the factual basis and severity. If insufficient grounds are found, the matter may be dismissed with reasons documented internally.

Where full investigation is needed, the Ethics Committee assigns the case, gathers evidence, and informs the subject of the allegations. The subject must cooperate fully and is strictly prohibited from tampering with evidence or influencing witnesses.

Upon completion, the Ethics Committee reviews findings and recommends appropriate action, ranging from disciplinary measures to legal proceedings. All outcomes are documented and reported to the Board of Directors. The whistleblower receives updates upon request, referencing the assigned report key.

Note: Detailed process steps and timelines are maintained within the Case Management System. Please refer to Appendix A for further details.

All complaints are initially received by the Compliance Officer (compliance@adorpower.com). Matters are reviewed under supervision of the Executive Director & COO. Complaints involving senior management are escalated directly to the Chairperson.

The escalation pathway is:

• Step 1: Compliance Officer
• Step 2: Executive Director & COO
• Step 3: Chairperson (final recourse)

Each escalation level aims to conclude its review within 10–15 working days.

Concerns should be raised promptly after awareness arises. Reports must include:

• Names and designations of individuals involved.
• Dates, times, and locations of incidents.
• A clear description of the alleged violation.
• Supporting evidence or identification of potential witnesses.
• Contact information (if the reporter is comfortable disclosing it).

Reporters should remain factual and avoid unsubstantiated accusations, personal investigations, or unnecessary discussions with colleagues. Evidence must be preserved in its original form. Failure to respond to follow-up requests within 7 working days may result in closure of the matter.

All complaints are handled with the strictest discretion. Information is shared exclusively on a need-to-know basis. Every participant, including the whistleblower, subject, investigators, and committee members, is obligated to maintain complete confidentiality.

The whistleblower’s identity may be disclosed only when:

• The whistleblower explicitly consents.
• Sharing is essential for the investigation or legal proceedings.
• Disclosure is compelled by law or court order.
• The complaint has been determined to be frivolous or malicious.

No employee or third party will face adverse consequences for raising concerns in good faith. Retaliation in any form is expressly prohibited, including termination, demotion, salary reduction, transfer, hostile work environment, threats, or intimidation.

Protection applies when disclosure is made in good faith and the whistleblower has a reasonable belief that the information is substantially accurate. Whistleblowers are not exempt from accountability for their own independent misconduct.

Any perceived retaliation must be reported immediately to:

• Compliance Officer: compliance@adorpower.com
• Human Resources: hr@adorpower.com
• Ombudsperson: whistleblower@adorpower.com

A complaint is classified as frivolous or malicious when lodged with deliberate intent to harm without credible factual basis, filed recklessly without reasonable belief in its truthfulness, or primarily intended to settle personal grievances.

Individuals found to have submitted such complaints may face disciplinary action up to and including termination, potential liability for damages, and referral to legal authorities. Good-faith errors are never penalized.