Whistleblowing & Grievance Policy

• Data-integrity breaches (fabrication, alteration, or omission of results).
• Bribery, corruption, fraud, or theft.
• Breaches of health, safety, or environmental law.
• Discrimination, harassment, or abusive behaviour.
• Serious breaches of client confidentiality or personal-data protection.
• Sanctions and export-control violations.
• Any deliberate concealment of any of the above.

• Speak in confidence with your line manager, or their manager.
• Email speakup@als-analytical.hk, which routes to the Independent Non-executive Chair without being visible to any operational manager.
• Use the independent EthicsPoint hotline: HK 800 906 234 (24/7, 20 languages) or ethicspoint.com/als-analytical.
• By post to Prof. Yasmin Iqbal, P.O. Box 68914, Kwun Tong Post Office, Kowloon (marked ‘private and confidential’).

Every reasonable step is taken to protect your identity. Anonymous reports are accepted; giving your name allows us to ask follow-up questions and tell you the outcome, but is not required.

Reprisals of any kind against a person who has reported in good faith are treated as a gross-misconduct offence. Where a person believes they have been retaliated against, they may report it directly to the Non-executive Chair.

• Acknowledgement within 1 business day (unless anonymous).
• Independent investigator appointed within 5 business days.
• Fact-finding, interviews, and evidence review.
• Substantive update within 30 calendar days (or an interim update, if the investigation is longer).
• Report to the Non-executive Chair and, for material matters, to the full board.
• Where wrongdoing is confirmed, remediation and — where appropriate — self-report to regulators.

You may also report to a competent public authority (e.g. HK ICAC, HK PCPD, HK Companies Registry, or a regulator in your own jurisdiction). This policy does not restrict your right to do so, and we do not require a prior internal report.