Whistle Blowing Policy

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The Board, including the Audit and Risk Management Committee (“ARMC”), is committed to maintaining a culture of integrity with the highest standards of openness and accountability in all of the Group’s business dealings and communications with all stakeholders. The Board does not believe that it is in any stakeholder’s or employee’s interest, with knowledge of wrongdoing, to remain silent.

This Whistle-Blowing Policy (“Policy”) is intended to provide a framework to promote responsible and secure whistle-blowing as well as to protect the Group’s business and reputation.
The Policy aims to provide an avenue for employees and external parties to raise concerns and offer reassurance that they will be protected from reprisals or victimisation for whistle-blowing in good faith. Employees of the Group and stakeholders, including but not limited to suppliers, vendors, clients, and contractors, may use the procedures set out in the Policy to report any concern or complaint regarding:
• questionable accounting or auditing matters
• internal control
• disclosure matters
• collusion with competitors, clients or suppliers
• misuse of confidential information
• serious breaches of Group policy
• misappropriation of assets and fund
• fraud, bribery and corruption
• deliberately concealing serious wrongdoings or malpractices
• improper matters which may cause financial and non-financial loss to the Group or damage to the Group’s reputation
The above list is not exhaustive.
In pursuit of this objective, the Group adopts, as its best practices, the Code of Corporate Governance 2018 issued by the Monetary Authority of Singapore or as may from time to time be amended.
Only genuine concerns should be reported under the Policy procedures. The report should be made in good faith with a reasonable belief that the information and any allegation in it are factual and substantially true, and the report is not made for personal gain. Malicious and false allegations will be viewed seriously and treated as gross misconduct and, if proven, may lead to disciplinary actions including dismissal.

The Group encourages employees and external parties to put their names to their allegations. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, considering the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided. All concerns and irregularities raised will be treated with the strictest confidence and every effort will be made to ensure that confidentiality is maintained.
Concerns may be raised verbally, by e-mail or in writing. As it is essential to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The complaint should include details of the parties involved, date or period of time, the type of concern, evidence substantiating the complaint where possible, and contact details, in case further information is required.
All complaints raised shall be directed to the ARMC Committee.

Mr. Basil Chan (Chairperson)
Ms. Kay Pang Ker-Wei, (Member)
Mr. Tommy Teo Zhi Zhuang, (Member)
Email: auditcommittee@nera.net
Mail: 19 Tai Seng Avenue, #06-01 Singapore 534054. Marked “Private & Confidential” to the Audit & Risk Management Committee Chairperson.

Discrimination, retaliation or harassment of any kind against a whistle-blower who submits a complaint or report in good faith will not be tolerated and appropriate steps will be taken to ensure the complainant suffers no detriment or retaliation.

All matters received will be reviewed within a reasonable time frame by the ARMC, and after due consideration and inquiry, a decision will be taken on whether or not to proceed with a detailed investigation.
Depending on the sensitivity, significance and nature of the concerns, the ARMC may direct the complaint to the appropriate party best placed to address it or lead the investigation or form a committee tasked to ensure prompt and appropriate investigation and resolution. Information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.
The ARMC reserves the right to refer any concerns or complaints to appropriate external regulatory authorities, external or internal auditors, external counsel, independent body or specialist third party so as to achieve greater transparency and commitment to address the issues raised. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to respond to such allegations. Employees who fail to co-operate in an investigation or deliberately provide false information during an investigation shall be subject to strict disciplinary action up to, and including, immediate dismissal.
If, at the conclusion of an investigation, the ARMC determines that a violation has occurred or the allegations are substantiated, effective remedial action commensurate with the severity of the offence will be taken.

Human Resources shall make available to all employees a copy of the Policy via website, email or shared drive.

ARMC has the responsibility for ensuring the maintenance, regular review and updating of the Policy. Revisions, amendments and alterations to the Policy can only be implemented by the approval of the Board of Directors with the recommendations of the ARMC. Changes will be notified in writing, website, email or shared drive to the employees when they occur.
PwC Risk Services Pte Ltd, internal auditors of the Group, will maintain the whistleblowing register.