The following words as used in this document shall have the meaning ascribed herein:
This policy applies to all directors and employees (including full-time, part-time and contract staff) in the Group, and external parties such as vendors, clients, contractors and other stakeholders.
The Company is committed to a high standard of ethical conduct and adopts a zero tolerance approach to fraud and unethical conduct. The Company will investigate reports of such matters in an objective manner and take the appropriate actions according to the outcome of the investigation. All reports will be handled by the 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 Action within the Group which the reporting person become aware of; and (iii)provide assurance that the reporting person will be protected from reprisals or victimisation for reporting in good faith and without malice.
The above list is not exhaustive.
In pursuit of this objective, the Company adopts as its best practices the Code of Corporate Governance 2012 issued by the Monetary Authority of Singapore, as may be amended from time to time.
Reporting of Possible Improprieties
Mun Siong 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.
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.
Right to file Complaint
Every employee and external parties 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.
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.
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.
Procedures for handling Complaints
The procedures for the receipt, retention and treatment of a Complaint are set out below and shall be complied with.
Submission of Complaint
Every Complaint shall be in writing via the Whistleblowing Report Form that will be lodged with the WIC. The complainant must provide his particulars as follows: (a)Name; (b) Organisation; (c) Contact Number; and (d) Email Address.
The Complaint would not be attended to if the above-mentioned particulars are not stated. The contact particulars are required to facilitate verification and investigation of the allegation. The WIC may require further information or clarifications and would therefore have to contact the reporting party.
For submission of all Complaints, please contact the WIC via this Whistleblowing Report Form.
Confidentiality of Identity
Every effort will be made to protect the confidentiality of the reporting party’s identity, save where it is required by law, or by the order or directive of a court of law, regulatory body or by the Singapore Exchange or such other body that has the jurisdiction and authority to require such identity to be revealed.
Registration of Complaints
The WIC shall maintain or cause to be maintained a Complaints Register for the purposes of recording all Complaints received, the date of such Complaint and nature of such complaint.
The WIC shall approve making the Complaints Register available for inspection upon any request by investigating authorities.
Review and Investigation of Complaint
Upon receipt of any Complaint, the WIC shall:
Determination by WIC
Upon receipt of any Complaint, the WIC may:
Any person who files a Complaint which is frivolous, in bad faith, in abuse of these policies and procedures, with malicious or mischievous intent will not be protected by this Document and may be subjected to administrative and/or disciplinary action, including but not limited to the termination of employment or other contract, as the case may be.
This Document shall be read in conjunction with any laws, regulations, rules, directives or guidelines that the Singapore Exchange Securities Trading Limited (“SGX-ST”), the Companies Act and/or Securities and Future Act (“SFA”) may from time to time prescribe or issue on the receipt, retention and/or treatment of Complaints regarding accounting, internal controls,operation matters or any matters governed by this policy.
In the event that any policy or procedure herein is inconsistent or in conflict with the laws, regulations, rules, directives or guidelines as prescribed by SGX-ST, the Companies Act and/or SFA or any part thereof, the laws, regulations, rules, directives or guidelines as prescribed by SGX-ST, Companies Act and/or SFA shall prevail to the extent of such inconsistency or conflict.
The WIC has the responsibility for ensuring the maintenance, reviewing regularly and updating of this policy. Revisions, amendments and alterations to this policy can only be implemented after it has been approved by the WIC and the Board of Directors. Any changes will be updated on the website when they occur.
A copy of this Document shall be available to all employees and stakeholders on the Company’s website.