Whistle-blowing Policy

1. Introduction

The SingLand group of companies is committed to conducting business that is consistent with high standards of corporate governance and in compliance with all laws and regulatory requirements. Therefore, we welcome information and feedback that may protect the interests of the Group and its stakeholders as well as maintain our commitment. The whistle-blowing policy (“policy”) was first established in February 2004 to provide employees and external parties a confidential, neutral and independent channel to report or feedback their concerns in matters related to the Group.

2. When Should You Whistle-blow?

2.1 Generally, the best way to communicate is by direct contact with Management; however, there may be occasions when you wish to discuss important issues but do not want your name or identity known by Management.
2.2 You should raise your concern at an early stage when you have genuine concern rather than wait for proof.

3. Who Can Whistle-blow And What Can You Whistle-blow?

3.1 Employees and external parties, such as customers, suppliers, contractors, and other stakeholders may use this policy to report or feedback on any of the following:
- 3.1.1 Theft or misappropriation of funds;
- 3.1.2 Financial malpractice or fraud;
- 3.1.3 Bribery and corruption;
- 3.1.4 Abuse and misrepresentation of authority;
- 3.1.5 Non-compliance with laws and regulations;
- 3.1.6 Discrimination by gender, age, race, religion, sexual orientation, or disabilities;
- 3.1.7 Workplace bullying and harassment;
- 3.1.8 Workplace safety and health lapses; and
- 3.1.9 Falsification of documents.
3.2 This policy will not address an issue that is covered by any trade union agreement or that should be dealt by applicable law.
3.3 This policy does not absolve you from your duty of confidentiality and care in the course of your work nor is it a route for taking up a grievance about a personal situation.

4. How Will Your Report And Information Be Maintained?

4.1 All reports raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.
4.2 Your personal data (if provided by you) will be protected in accordance with the Personal Data Protection Act of Singapore, and will not be disclosed without your consent unless disclosure is compelled by a court of law or there appears to be imminent risk of serious harm if not disclosed.

5. Can You Make An Anonymous Report?

5.1 We recognise that you may want to raise a concern in confidence under this policy, and we will consider, as far as is reasonably practicable, reports raised anonymously. If you do not reveal who you are, we will be unable to respond to you, and it will also make the task of investigating your report or feedback more difficult and less effective.
5.2 The outcome of the investigation hinges on your report. Therefore, if you choose to remain anonymous and do not provide any evidence that we can independently verify, your report may or may not be investigated at the discretion of the Audit & Risk Committee.
5.3 Your report may eventually lead to the protection of the Group’s reputation and/or the prevention/recovery of any financial loss for which we may consider a commendation provided you reveal your identity.

6. What Happens After You Make A Report?

6.1 All reports will be evaluated within a reasonable timeframe, and after due consideration, a decision will be made whether to proceed with a formal investigation. The formal investigation may be conducted by the Internal Audit Department or be directed to a department/business unit best placed to address it. Guidance may be sought from the Audit & Risk Committee, CEO and/or other appropriate parties depending on the matters reported.
6.2 If the report relates to a Senior Management Executive or CEO, the report will be escalated directly to the Chairman of the Audit & Risk Committee.
6.3 Your report will be acknowledged in writing, and you will be informed as to:
- 6.3.1 Who is handling your report; and
- 6.3.2 How you can contact the person handling the report.
6.4 You may be contacted if further assistance/information is required from you.
6.5 The person handling the report may write to you summarising your concerns and setting out what is likely to happen next.
6.6 Once the investigation is completed, you will be advised of the outcome in writing. Please note that it may not be possible to tell you the precise action taken.
6.7 All whistle-blowing cases will be reported to the Audit & Risk Committee.
6.8 We have zero tolerance for unethical conduct and acts which are non-compliant with regulatory requirements or internal policies. Any employee found guilty of such conduct and acts will be dealt with swiftly, and appropriate cases will be reported to the relevant authorities.

7. How Long Will It Take To Address Your Report?

Less complicated issues are processed within 10 to 20 working days. However, to process more complex issues, Management may need additional time. In those cases, the person handling the report will notify you.

8. How Will You Be Protected After Making A Report?

8.1 This policy provides assurance to you that you will not be victimised nor taken to task if you have acted in good faith, and made the report with no malicious intent.
8.2 We do not tolerate retaliatory action (i.e., harassment, intimidation or victimisation) against anyone raising a genuine concern. Employees found to have engaged in retaliatory conduct will be subject to disciplinary action, i.e., written warnings up to and including termination of employment.
8.3 Please inform the investigating officer if you have been subjected to any retaliatory action.

9. Why You Should Not Make A False Or Frivolous Report?

9.1 Disciplinary action, i.e., written warnings up to and including termination of employment, will be taken against anyone who maliciously or frivolously raises a report that is known to be untrue.
9.2 We may refer malicious or frivolous reports raised by external parties which are known to be untrue to the relevant authorities.

10. What Information Should You Provide When Contacting Us?

10.1 Please declare at the onset if you have any personal interest in the report.
10.2 Please provide specific details of your concern such as:
- 10.2.1 What misconduct/improper activity occurred?
- 10.2.2 Who is/are involved in the misconduct/improper activity?
- 10.2.3 When did it happen and is it still happening?
- 10.2.4 When did you notice it?
- 10.2.5 Where did it happen?
- 10.2.6 How did it happen?

11. How To Contact Us?

11.2 Whistle-blowing reports involving the Head of Internal Audit may be referred directly to the Chairman of the Audit & Risk Committee by sending an e-mail to: ac.chairman@singaporeland.com.

12. Amendment To The Policy

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