Xin Yuan Comcare Ltd
Whistleblowing Policy 2023

Xin Yuan Comcare Ltd (XYCL) is committed to a high standard of transparency, integrity, compliance and accountability.

The Whistleblowing Policy aims to provide an avenue for employees, vendors, beneficiaries and other stakeholders to express genuine concerns on any serious wrongdoing/malpractice that infringes on XYCL’s Code of Conduct or violates the law so that XYCL may take relevant action.

Purpose of Policy

This Policy aims to achieve:
a. Provide a trusted avenue for employees, vendors, beneficiaries and other stakeholders to
report serious wrongdoings or concerns without fear of reprisals when whistleblowing in good faith.
b. Promote standards for good financial and corporate practices and to deter wrongdoing.
c. Encourage employees to raise concerns at an early stage to an internal authority so that
actions could be taken immediately to resolve them.

Reportable Incidents

Some examples (though not exhaustive) of reportable incidents covered by this policy:
a. General malpractice such as immoral, illegal or unethical conduct.
b. Potential infractions of XYCL’s Code of Conduct.
c. Impropriety, corruption, theft/misuse of XYCL’s properties/assets/resources.
d. Any other serious improper matters which may cause financial or non-financial loss to XYCC
or damage XYCC’s reputation.


Concerns may be raised with, or information provided to our Vice President, Dr Christina Lau, PBM via email to: [email protected] or via the Whistleblowing Report e-Form below. The individual is encouraged to identify himself/herself and provide relevant contact details in case further clarification or information is required. To enable investigation, the individual should provide details such as parties involved, date and time of the incident, description of incident and evidence or any other information to substantiate the concern.

All concerns raised will be independently reviewed by the Audit Committee. All information provided will be kept strictly confidential.

Please consider using email correspondence ([email protected]) if you have attachments larger than 50MB.