Obligation of the CFO
All Reports sent to the Chief Financial Officer must promptly undergo an initial review by the Chief Financial Officer, who must:
a. promptly forward to the Audit Committee any Report involving the Company’s senior officials or having an actual or potential misreporting or loss to the Company that could have a material adverse effect on the Company’s reputation or financial statements and
b. promptly determine whether to commence an investigation of all other Reports
The Financial Officer may, in his/her reasonable discretion, determine not to commence an investigation if the Report contains only unspecified or broad allegations of wrongdoing without appropriate informational support, or if the Report is not credible. This decision shall be reported to the Audit Committee at its next ordinary meeting and shall, to the extent appropriate, be made known to the Complainant who submitted the Report. The Audit Committee may, however, not accept this decision, in which case it will determine whether the Audit Committee or the Chief Financial Officer will investigate the Report, taking into account the factors described below. If the Chief Financial Officer determines that an investigation must be conducted, he/she will promptly commence the investigation. The Chief Financial Officer shall also promptly investigate other Reports as requested in writing by the Audit Committee. The Chief Financial Officer shall report the findings of the investigations conducted pursuant to this Section to the Audit Committee.
Cautions in consultations
The Chief Financial Officer may consult with any member of management who is not the subject of an accounting allegation, legal allegation or retaliatory act included in the Report and who may have appropriate expertise to provide assistance in connection with the investigation of the Report. The Chief Financial Officer may also engage independent accountants, counsel or other experts to assist in the investigation of Reports and analysis of results, if necessary or appropriate.
Reporting obligation of the CFO
The Chief Financial Officer shall, at every Audit Committee’s ordinary meeting, present a summary of all the Reports received by, or forwarded to the CFO (including those Reports that the CFO decided not to investigate) and all the material developments, findings and conclusions of investigations since the previous meeting. The Audit Committee may or may not accept such findings and conclusions. The Chief Financial Officer shall provide such additional information regarding any Report or investigation as may be requested by the Audit Committee.