1.1 This Policy aims to:
1.2. The Company’s Audit Committee (the “Audit Committee”) shall be responsible for oversight and monitoring of any whistleblowing matters (including any amendments to this Policy).
2. WHAT TO REPORT
2.1. You are encouraged to come forward to report any reasonable concern of misconduct, malpractice or wrongdoing that comes to your attention, including but not limited to the following:
2.2 Personal grievances and complaints, customer service complaints as well as personal disputes are not covered under this Policy.
3. REPORTING A CONCERN
3.1. Whistleblowers may report whistleblowing concerns through the following channels:
For proper documentation and records, whistleblowers are encouraged to submit their concern via email or mail.
3.2 All the whistleblowing concern received will be submitted to the Audit Committee.
3.3 Whistleblowers are strongly encouraged to identify themselves when reporting a concern so that appropriate follow-up questions and investigations can be conducted. Concerns expressed anonymously may be investigated after given due consideration to the following:
3.4 The Company is committed to ensure protection of the whistleblower against detrimental or unfair treatment. Disciplinary action (including dismissal) shall be taken against any person who:
4. HANDLING A REPORTABLE CONCERN
4.1. The Company will undertake each case with impartiality, fairness and confidentiality.
4.2. The identity of the whistleblower will be kept confidential, with disclosure on a need-to-know basis to the following:
the Audit Committee;
4.3. The whistleblower’s consent will be obtained prior to disclosing his/her identity to anyone other than in those identified above.
4.4 All whistleblowing matters shall be properly documented and filed. Whistleblowing concern reported though a phone call shall be logged by the receiver and emailed to the Audit Committee for documentation purposes.
4.5 Upon receipt of the whistleblowing concern, the Audit Committee will carry out an initial assessment to determine if an investigation is required and the scope of the investigation.
4.6 If the whistleblowing concern involves a member of the Audit Committee, the Audit Committee member shall abstain from participating in the investigation or discussion so that the concern may be investigated independently.
4.7 The Audit Committee shall nominate an independent investigation team to conduct the investigation. All members of the investigation team shall be independent of the whistleblowing concern and conduct the investigation impartially.
4.8 The investigation team may contact the whistleblower and any party deemed relevant by the investigation team for further information to conduct its investigation. Individuals who are interviewed or asked to provide information are obliged to fully cooperate with the investigation team and must refrain from discussing or disclosing matters concerning the investigations.
4.9 Depending on the nature of the concern raised or information provided, the investigation team (at the consent of the Audit Committee) may consult external and/or internal auditors, private investigators or specialist/experts with relevant knowledge or experience to assist with the investigation.
4.10 The investigation team is expected to handle all matters seriously, confidentially and promptly. An investigation report, remedial actions and recommendation of improvement to the Group’s policies and procedures to prevent future misconduct, malpractice or wrongdoing, if any, shall be submitted by the investigation team to the Audit Committee for review within four (4) weeks (or longer as approved by the Audit Committee) from the forming of the investigation team.
4.11 Based on the outcome of the investigation, the Audit Committee shall determine the appropriate actions to address and rectify the whistleblowing concern, including but not limited to dismissal or referring to the relevant law enforcement authority, if required. All actions shall be tabled to the Board of Directors for approval before implementation.
4.12 Investigation results are confidential and will not be disclosed or discussed with anyone other than those with a legitimate need to know. While the whistleblower will be informed of the outcome, the whistleblower shall not be entitled to the information or reports collated by the investigation team in the course of the investigation.
4.13 If the investigation concludes that a whistleblower has made false allegations maliciously, in bad faith or with a view to personal gain, the whistleblower may be subject to applicable legal action or internal disciplinary actions.
4.14 The Company will make periodic whistleblowing reports at its board meetings. A “NIL” report is required if there is no whistleblowing event during the reported period.
5. EXTERNAL DISCLOSURES
5.1 The Company shall not, except in the course of duty or under compulsion by law or SGX-ST rules, disclose, divulge or make public any information of a confidential nature relating to the details of the alleged misconduct, malpractice or wrongdoing. The Company shall ensure that the identity of the whistleblower is kept confidential.
This Whistleblowing Policy (this “Policy”) is last updated on 16 December 2021.