1. Purpose

  1. This Policy provides a reliable system for a person to report any wrongdoings, including suspected violation of Southland Global Pte. Ltd. (SGPL)’s Code of Conduct, Group Policies, or any applicable laws and regulations without fear of reprisal when whistleblowing in good faith.
  2. The effective implementation of this Whistle-blowing Policy shall be overseen by SGPL Compliance Committee and supervised by SGPL Compliance Director.

2. Scope

  1. This policy applies to all persons including employees (the Board of directors, Managers, Officers, and full-time/part-time/permanent/contract employees) and stakeholders of SGPL (SGPL Group).

3. Application

  1. This Whistle-blowing Policy allows for reporting by Employees or stakeholders of SGPL Group to SGPL Compliance Committee without fear of reprisal, discrimination, or adverse consequences and also permits SGPL Compliance Committee to address such reports by taking appropriate action, including but not limited to disciplining or terminating the employment and/or those responsible.
  2. Reportable incidents for Whistle-blowing include:
    1. Breach of SGPL Code of Conduct and Group Policies
    2. Violation of regulations in SGPL Group Companies
    3. Failure to comply with applicable laws and regulations
    4. All forms of financial or non-financial malpractices or impropriety such as fraud, corruption, bribery or theft
    5. Harassment and abuse of power and authority
    6. Actions detrimental to health and safety of people and to the environment
    7. Discrimination on gender, race, disabilities
    8. Serious conflict of interest without disclosure
    9. Concealing information about any of the above

4. Definition

  1. A Whistle-blower is any person, including SGPL Group Employees and Stakeholders, who voluntarily reports disclosure of individual or organizational malpractice or suspected or anticipated malpractice stated in paragraph 3b above.
  2. Receiving officer refers to a member of SGPL Compliance Committee.
  3. Investigation Team appointed by SGPL Compliance Director to conduct investigation into any suspected malpractice.

5. Reporting Mechanism

  1. SGPL encourages Whistle-blowers who report their concerns to provide their names, contact details, position in SGPL Group or relationship with SGPL Group whenever possible.
  2. Concerns reported anonymously will be taken up depending on the following:
    1. Seriousness of issues
    2. Significance and credibility of concerns
    3. Likelihood of the report being verifiable
  3. Concerns may be raised verbally or in writing and for SGPL to be able to effectively evaluate and investigate.
  4. The report should provide as much as details or specific as possible:
    1. Names of people and/or organization involved
    2. Details of the incident (what, where, when)
    3. Any supporting evidence
  5. The contact details of the Receiving officer are:
    1. Address: 8 Cross Street #27-01 Manulife Tower S (048424)
    2. Hotline: +65-92278865
    3. Email: whistleblow@southlandglobal.com

6. Confidentiality and Non-Retaliation

  1. The Identity of the Whistle-blower shall be kept confidential within SGPL Compliance Committee and its Investigation Team. SGPL Compliance directors will seek the Whistle-blower’s consent in case of need to disclose to anyone other than SGPL Compliance Committee and its Investigation Team.
  2. SGPL prohibits discrimination, retaliation, or harassment of any kind against any Whistle-blower who reports a concern in good faith. Such conduct is a breach of SGPL Group Code of Conduct and anyone who engages in retaliation against a Whistle-blower may be subject to disciplinary action.
  3. If Whistle-blower believes in being subjected to discrimination, retaliation, or harassment for having made a report, he or she can immediately report the facts to the SGPL Compliance Committee for its prompt investigation and appropriate action.
  4. All information disclosed during the investigation will remain confidential, except as necessary to conduct the investigation and to take any corrective action in accordance with applicable laws and regulations.
  5. SGPL reserves the right to refer any concerns or complaints to appropriate external regulatory authorities.
  6. Depending on the nature of the complaint, the subject of the complaint may be informed of the report against him or her and be provided with an opportunity to reply to such a report.

7. Handling Procedures

  1. If at the conclusion of an investigation, SGPL determines that a violation has occurred or the allegations are substantiated, appropriate disciplinary action in accordance with applicable Company Regulations and the Employment Agreement will be taken.
  2. Any disciplinary action will be recommended by SGPL Compliance Committee to the CEO.
  3. The respective business units are expected to undertake any recovery and remediation actions identified by the Investigation Team subsequent to an investigation.
  4. A non-anonymous whistle-blower will be informed that action has been taken at the conclusion of the investigation, without divulging confidential information.
  5. If an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her.
  6. Likewise, if investigations reveal that the External Party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

8. Communication, Clarification and Review of the Policy

  1. The Whistle-blowing Policy shall be communicated:
    1. To all new Employees during the orientation and compliance training;
    2. To all Employees as part of compulsory refresher training; and
    3. When requested by SGPL Compliance Committee or SGPL Compliance Director.
  2. Principles of the Whistle-blowing Policy shall be communicated to all relevant
    stakeholders.
  3. The Whistle-blowing Policy shall be reviewed regularly, where SPGL may modify this Policy to maintain compliance with applicable laws and regulations or organizational changes. The review should be carried out by the Compliance Director.

Signed on: 2 November 2020

Mr. Leong Tim Fook

___________________
Mr. Leong Tim Fook
Compliance Director
Southland Global Pte. Ltd.