What is Whistleblowing?

In broad terms ‘Whistleblowing’ means the reporting of suspected misconduct, illegal acts or failure to abide by any of the policies that Skilled Migration Group Limited has put in place to ensure adherence to all laws and obligations, or the code of conduct.

The aim of this Policy is to encourage employees and others who have suspicions or serious concerns regarding any aspect of the way that Skilled Migration Group Limited or its clients conducts business, or operates, and to come forward and raise any concerns.

Employees are often the only people to suspect that there may be wrong doing occurring. And ‘Whistleblowing’ is viewed by Skilled Migration Group Limited as a positive act that can make a valuable contribution to maintaining the ethical and good standing reputation that Skilled Migration Group Limited has, ensuring legal compliance at all times, and goes a long way to ensure the long-term success of our business.

Skilled Migration Group Limited do not consider it to be disloyal to colleagues or clients to speak up.

Skilled Migration Group Limited is committed to achieving the highest possible standards of service and the highest possible ethical legal standards in every aspect of its business.

To help achieve these standards it encourages the freedom to speak up.

If you are considering raising a concern, this Policy explains:

• issues that can be raised
• how whistle-blower’s will be protected
• how to raise your concern
• What action Skilled Migration Group Limited will take

Whistleblower policy aims

The Policy is put in place to ensure that concerns can be raised about suspected issues without fear of any disadvantage or dismissal.

The intent is to:

• Encourage anyone to feel confident in raising suspected concerns at the earliest opportunity.
• Explain ways for you to raise suspicious actions or concerns and receive information on action taken.
• Make sure that you receive a response to your concerns.
• Encourage you to understand that you will be protected from possible reprisals or victimisation if you make any disclosure in good faith.

Policy Scope

This Policy is intended to enable those who become aware of wrongdoing to report their concerns at the earliest opportunity so that they can be properly investigated.

The Whistle Blowing Policy does not replace existing procedures:

• If your issue relates to treatment as an employee, it should be raised with HR under the existing HR procedures.
• Client who have concerns about services provided, should raise any service related concerns with the GM of Skilled Migration Group Limited.

This Policy applies to all

The Policy applies to all:

• Employees of Skilled Migration Group Limited
• Subcontractors and their employees
• Clients and their employees

What should be reported

Any suspicion or serious concerns that you have about breaches of law or legislation, sanctions, or code of conduct by Skilled Migration Group Limited, its owners, employees, subcontractors or clients that:

• Make you feel uncomfortable in terms of legality or policy;
• Do not meet the high ethical standards required by Skilled Migration Group Limited
• Are no proper behaviour.

These might include, but is not limited to:

• Conduct which is a criminal offence or a breach of the law (a criminal offence has been committed or failing to comply with any other legal obligation)
• Unauthorised use of company or client funds or other assets
• Potential fraud and or corruption
• Any other unethical conduct.

Whistleblower Protection

This policy provides protection to any employee against dismissal or allow them to be victimised on the basis that they have made an appropriate lawful disclosure in accordance with this policy.

If it is the employee that has participated in the action causing concern. It is in the employee’s best interest to raise this as soon as possible. Under these circumstances Skilled Migration Group Limited cannot promise not to act against such an employee, but the fact that they raised the issue will be taken into account.

Harassment after raising any concern

Skilled Migration Group Limited is committed to good practice and as a highly ethical company holds itself to high standards and to being supportive of all of its employees.

Making a decision to report a concern can be a difficult one to make.  If you honestly and reasonably believe what you are reporting is true, you should have nothing to fear because you will be doing your duty to Skilled Migration Group Limited, your co-workers and its clients.

Skilled Migration Group Limited will take appropriate action to protect you when you raise a concern in good faith.

Whistleblower support

During this process:

• You will be given full support from Skilled Migration Group Limited
• Your suspicions and concerns will be taken seriously
• Skilled Migration Group Limited will help you throughout the investigation

If required, Skilled Migration Group Limited will consider re-deploying you for the period of the investigation.

For those that are not employees of Skilled Migration Group Limited, Skilled Migration Group Limited will venture to provide appropriate support wherever possible.

Confidentiality

All suspicions and concerns will be treated in confidence and every effort will be made not to reveal your identity.  If disciplinary or legal proceedings commence as a result of the investigation, it may not be possible to take action as a result of your disclosure without your help, so you may be asked to come forward as a witness.

Malicious allegations

If you make an allegation in good faith, reasonably believing it to be true, but it is not able to be substantiated or confirmed by the investigation, Skilled Migration Group Limited will recognise your concern and you will face no action.  If however, you make a malicious allegation, appropriate action that could include disciplinary action, may be taken.

How to raise a concern

This will depend on the seriousness and sensitivity of the issues involved and who is suspected of the wrongdoing.

You should raise concerns with:

The General Manager

The address for correspondence is

The General Manager

Skilled Migration Group Limited,

On Hong Commercial Building,

145 Hennessy Road,

Wan Chai, 999077,

Hong Kong SAR

If, exceptionally, the concern is about the General Manager of Skilled Migration Group Limited your concern could be raised with the Hong Kong authority under which Skilled Migration Group Limited is registered and operates, who will decide how the investigation will proceed. This may include external investigation.

The earlier you express your suspicions or concern, the easier it is to take action.  You will need to provide the following information:

• the nature of your concern and why you believe it to be true
• the background and history of the concern (giving relevant dates)

Although you are not expected to prove your suspicion, you will be required to demonstrate that you have a genuinely suspect a breach of the law, wrongdoing or malpractice and that there are reasonable grounds for your concern.

You may wish to consider discussing your concern with a colleague first and you may find it easier to raise the matter if there are two (or more) of you who have had the same experience or concerns.

You may invite your trade union, professional association representative or a friend to be present for support during any meetings or interviews in connection with the concerns you have raised.

What action will Skilled Migration Group Limited take

Skilled Migration Group Limited will respond to your concerns as quickly as possible.  Do not forget that investigating your concerns is not the same as either accepting or rejecting them.

Any investigation undertaken may need to be carried out under terms of strict confidentiality, by not informing the subject of the complaint until (or if) it becomes necessary to do so.

However, in some cases, such as allegations of ill treatment of others, immediate suspension from work may have to be considered.

Concerns raised may:

• be investigated by management, internal audit, or through the disciplinary/grievance process
• be referred to the police or financial conduct authority
• be referred to an external auditor

Within fourteen working days of a concern being raised, Skilled Migration Group Limited will write to you:

• acknowledging that the concern has been received
• indicating how Skilled Migration Group Limited proposes to deal with the concern
• provide you with employee support if you are an employee
• inform you whether further investigation will take place and if not, why not.

Potentially you will be interviewed to ensure that your disclosure is fully understood.

Any interview can be away from your usual place of work and a union or professional association representative or a friend may accompany you to provide support.

Skilled Migration Group Limited will minimise any difficulties that you may experience as a result of raising a concern.  And if you are asked to give evidence in any criminal or disciplinary proceedings, Global Skilled Migration Group Limited will arrange for you to receive appropriate advice and support.

Unless there are any legal reasons why it is not possible, you will be kept informed of any investigation its outcome.

You are duty bound not disclose information that is confidential to Skilled Migration Group Limited or confidential to anyone else, such as a client or contractor of Skilled Migration Group Limited, except to the appropriate points of contact under this whistleblower policy.

This Policy does not prevent you from taking your own legal advice.

Recording concerns

Skilled Migration Group Limited will maintain a corporate register containing all concerns that are brought to its attention.
The corporate register together with the annual reports will be available for inspection by internal and external audit, after removing any confidential details.

Policy review date

Policy last reviewed and updated 07 June 2025