GIL is committed to high standards of openness, integrity and accountability. In line with this commitment, GIL’s Whistleblowing Policy aims to provide an avenue for interested parties such as employees of the manager of GIL (“Manager”), shareholders and vendors with serious concerns to come forward and raise their concerns (“Whistleblowers”).

This Policy is intended to facilitate whistleblowing relating to, among others:

  • concerns about GIL’s accounting, internal controls or auditing matters;
  • impropriety, corruption, acts of fraud, theft and/misuse of GIL’s properties, assets or resources;
  • conduct which is an offence or breach of law;
  • abuse of power or authority; and
  • serious conflicts of interest not disclosed.

A Whistleblower should raise his concern or complaint by email to the Chairman of the ARMC at

Alternatively, he could also raise his concern independently to any director of GIL. This Policy does not disregard anonymous complaints and every effort will be made to protect the Whistleblower’s identity.

All concerns raised will be objectively investigated and appropriate follow-up actions will be taken. The Manager also keeps a register of queries to handle investors’ queries and complaints. In any case, if any of the concerns raised is related to any improprieties or misconduct of GIL, an independent investigation shall be conducted. The ARMC is responsible for the review of any concerns raised through the whistleblowing arrangements at its quarterly meetings. The ARMC has the power to appoint investigating officers and effect disciplinary follow-up action.

Reprisal or retaliation against any person for making a report, or intending to raise a complaint, or against anyone participating in the investigation of reported violations of this policy is strictly prohibited. Any acts of obstruction of reporting or investigation of a violation will not be condoned.