Compliance

Whistleblowing Policy & Procedure

Purpose & Scope

• In.Corp Global Pte Ltd and its subsidiaries (the “Group”) do not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff in the course of their work.
• This Whistleblowing Policy (the “Policy”) is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences.
• Employees and outside parties, such as suppliers, customers, contractors and other stakeholders, may use the procedures set out in the Policy to report any concern or complaint regarding:
  • questionable accounting or auditing matters
  • internal controls
  • disclosure matters
  • conflict of interest
  • insider trading
  • collusion with competitors
  • serious breaches of Group policy
  • unsafe work practices or
  • any other matters involving fraud, corruption and employee misconduct.
• The Policy allows for reporting by employees or outside parties of such matters without fear of reprisal, discrimination or adverse consequences, and also permits the Group to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.
• However, while the Policy is meant to protect genuine whistle-blowers from any unfair treatment as a result of their report, it strictly prohibits frivolous and bogus complaints.
• The Policy is also not a route for taking up personal grievances. These should continue to be taken up directly with the Management.

Reporting Mechanisms

• All employees and outside parties are encouraged to put their names and contact information to their allegations, so that clarifications can be sought during the course of the investigation.
• Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided.
• All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.
• As it is essential to have all critical information in order to effectively evaluate and investigate a complaint, the report made should provide as much detail of the incident. The complaint should include details of the parties involved, dates 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 should be reported to:

  Receiving Officer : The Chairman of the Audit and Risk Committee (c/o Group Chief Compliance Officer)
  Address : 30 Cecil Street, #19-08 Prudential Tower, Singapore 049712
  Email : [email protected]

• Complaints raised to other parties within the Group will be directed to the Receiving Officer, who is responsible for maintaining a centralized repository of all reported cases and ensuring that issues raised are properly resolved.
• All matters reported will be reviewed within a reasonable timeframe, and after due consideration and inquiry, a decision will be taken on whether to proceed with a detailed investigation.

Safeguards

• The Group prohibits discrimination, retaliation or harassment of any kind against a whistle-blower who submits a complaint or report in good faith.
• If a whistle-blower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the Receiving Officer. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.
• At the appropriate time, the party making the report/complaint may need to come forward as a witness.
• If an employee or outside party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her.
• If, however, an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the outside party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.