Privacy Policies

1. The Company is committed towards upholding a high standard of ethical conduct and therefore adopts a zero tolerance approach on issues/incidents relating to fraud and unethical conduct. The Company will review and investigate all such reports in an objective manner and, having considered the nature of the reported issue and the outcome of the investigation, will take appropriate actions. All reports will be handled by the Whistleblowing Investigation Committee (“WIC”) and any investigation and recommendation will be directed by the WIC.

This policy aims to (i) ensure independent investigation of the matters reported; (ii) provide an avenue to any individual (reporting person) to raise concerns about possible improprieties and obstructive actions within the Group which the reporting person becomes aware of; and (iii) provide assurance that the reporting person will be protected from reprisals or victimization for reporting in good faith and without malice.

This policy is intended to cover serious concerns that could have an impact on the Company such as actions or behavior that:

• May lead to incorrect financial reporting;

• Are unlawful;

• Are not in line with a legal obligation or policy of the Group;

• May pose dangers to the health and safety of any individual;

• May damage or cause potential damage to the environment;

• Amount to professional or ethical malpractices;

• Deliberately conceal serious wrongdoings or malpractices;

• May pose serious breach of fundamental internal controls;

• Otherwise amount to serious improper conduct; or

• Deliberately conceal information tending to show any of the above

The above list is not exhaustive.

In pursuit of this objective, the Company adopts as its best practices, the principles and guidelines of the Code of Corporate Governance issued by the Monetary Authority of Singapore, as may be amended from time to time.

2. Reporting of Possible Improprieties

The Company believes that it is in the best interest of the Group to promote a conducive environment for employees and external parties to raise or report concerns about possible improprieties which they may encounter in full confidence and without fear of retaliatory action.

3. Authority to receive Complaints

It is hereby determined that all Complaints shall be reported in writing to the WIC of the Company via the Whistleblowing Report Form.

4. Right to file Complaint

Every employee and external party shall have unfettered right to file a complaint in good faith without malice or consideration of personal benefit. Such parties shall not be restricted in the exercise of such right as a reporting party. They are not investigators or finders of fact, nor do they determine the appropriate corrective or remedial action that may be warranted.

5. Prohibition of Obstructive Action

The Company will not tolerate nor condone any obstructive action being taken against any employee who wishes or intends to, or who is in the process of filing a complaint, and may institute disciplinary action or assist the said employee in taking a legal action, as it deems appropriate, against anyone found to have taken such obstructive action.

6. Prohibition of Retaliatory Action

The Company will not tolerate nor condone any retaliatory action taken against any reporting party who has filed a complaint and may institute disciplinary action against any employee or person found to have taken such retaliatory action.

Any report alleging retaliatory action or obstructive action will be received, reviewed and investigated by WIC in the same manner as any report alleging possible improprieties.

The above shall not preclude any administrative, disciplinary and/or other action being taken against any person who has committed or abetted the commission of the possible improprieties which is the subject matter of the complaint, notwithstanding that the person is the complainant or a witness in the investigation. However, the WIC would take into account the fact that he/she has co-operated by filing the complaint or provided information or documents as a witness to facilitate an investigation.