Policy On Reporting Possible Improprieties In Matters Of Financial Reporting, Internal Control Or Other Matters

The Company is committed to achieving and maintaining the highest standards of openness, probity and accountability. In line with this commitment, the Company expects and encourages its employees and those who deal with the Company (e.g. customers, suppliers, creditors and debtors) to report to the Company any suspected impropriety, misconduct or malpractice within the Company.

A Policy on Reporting Possible Improprieties in Matters of Financial Reporting, Internal Control or Other Matters (“Whistleblowing Policy”) has been adopted by the Company to provide reporting channels and guidance on reporting possible improprieties in matters of financial reporting, internal control or other matters. It also provides reassurance to the whistleblowers of the protection that the Company will extend to them against unfair dismissal or victimisation for any genuine reports made under the Whistleblowing Policy.

The Whistleblowing Policy applies to the Board of Commissioners, the Board of Directors and all employees of the Company as well as independent third parties who deal with the Company.

Any report of impropriety, misconduct or malpractice shall be addressed to the Head of Internal Audit Unit who shall then report to the Chairperson of the Audit Committee for determining the course of action to pursue, with power to delegate, with respect to the report. The format and length of an investigation will vary depending upon the nature and particular circumstances of each report made. The report raised may be investigated internally, and/or referred to the external auditor and/or the relevant public or regulatory bodies.

Each report will be treated as confidential and the identity of the reporter will not be divulged save with such reporter’s consent or under special circumstances and in compliance with any applicable laws or regulations.

The reporter will be assured of protection against unfair dismissal, victimisation or unwarranted disciplinary action, even if the report is subsequently proved to be incorrect or unsubstantiated. Harassment or victimisation of a genuine reporter is treated as gross misconduct, which if proven, may result in dismissal. The Audit Committee shall supervise the enforcement of the Whistleblowing Policy and is responsible for the interpretation and review of all the policies and procedures set out therein. In 2022, there was no whistleblowing report of suspected improper activities.