Compliance

WHISTLEBLOWING POLICY

1.

POLICY

1.1 It is the desire and aim of the Company to develop, promote and maintain high standards of corporate governance within the Group.
1.2 This policy aims to provide an avenue for stakeholders to raise concerns about Possible Improprieties within the Group which they become aware of and to provide reassurance that they will be protected from reprisals or victimisation for whistleblowing in good faith and without malice.
1.3 In pursuit of this objective, the Company adopts as its best practices the Code of Corporate Governance 2018 issued by the Council on Corporate Disclosure and Governance, as may from time to time be amended.
1.4 This policy is subject to regular review by the Company’s management.

2.

SCOPE

2.1  This policy applies to all current or former:
  - Employee of the Group;
  - Contractor or supplier of goods or services to the Group, or their current and former employee;
  - Associate of the Group; or
  - Family member of an individual mentioned above.
2.2 Possible Improprieties
  This policy is intended to cover serious concerns that could have an impact on the Group such as actions that:
  - May lead to incorrect financial reporting;
  - Are unlawful;
  - Are not in line with a legal obligation or a policy of the Group;
  - May pose dangers to the health and safety of an individual;
  - May damage or cause potential damage to the environment;
  - Amount to professional or ethical malpractices;
  - Deliberately conceal serious wrongdoings or malpractices;
  - May pose serious breach of fundamental internal controls;
  - Otherwise amount to serious improper conduct; or
  - Deliberately conceal information tending to show any of the above.
  The above list is not exhaustive.  However, Complaints cannot be made under this policy solely for personal work-related grievances.

3.

AUTHORITY TO RECEIVE COMPLAINTS

3.1 All Complaints shall be reported to the Company either in person or in writing at whistleblowing@gkgoh.com or the following address:
  Chairman of Audit Committee
  G. K. Goh Holdings Limited
  50 Raffles Place #33-00
  Singapore Land Tower
  Singapore 048623
3.2 Everyone shall have unfettered right to file a Complaint and shall not be restricted in the exercise of such right.

4. 

PROTECTION AGAINST VICTIMISATION

4.1  Confidentiality of Identity
  Every effort will be made to protect the complainant’s identity. The identity of the complainant shall be confidential save where:
4.1.1 the identity of the complainant, in the opinion of the Audit Committee (“AC”), is material to any investigation;
4.1.2  it is required by law, or by the order or directive of a court of law, regulatory body or by the Singapore Exchange or such other body that has the jurisdiction and authority of the law to require such identity to be revealed;
4.1.3 the AC with the concurrence of the Board of Directors opined that it would be in the best interests of the Group to disclose the identity;
4.1.4 it is determined that the Complaint was frivolous, in bad faith, or in abuse of these policies and procedures and lodged with malicious or mischievous intent; or
4.1.5 the identity of such employee is already public knowledge.
4.2 Prohibition of Obstructive Action
  The Company objects to and does not tolerate nor condone any Obstructive Action being taken against anyone who wishes or intends to, or who is in the process of filing a Complaint, and may institute disciplinary action or assist the said complainant in taking a legal action, as it deems appropriate, against any person found to have taken such Obstructive Action.
4.3 Prohibition of Retaliatory Action
  The Company objects to and does not tolerate nor condone any Retaliatory Action taken against anyone who has filed a complaint alleging Possible Improprieties and may institute disciplinary action or assist the said employee, against any employee or person found to have taken such Retaliatory Action.
4.4
Any complaint alleging Obtrusive Action or Retaliatory Action shall be received, reviewed and investigated by the Company in the same manner as any complaint alleging Possible Improprieties.
4.5 
The above shall not preclude any administrative, disciplinary and/or other action being taken against any person who has committed or abetted the commission of the possible impropriety which is the subject matter of the Complaint notwithstanding that the person is the complainant or a witness in the investigation though the AC would take into account the fact that he/she has cooperated by filing the Complaint or provided information or documents as a witness.

5.

PROCEDURES

5.1 
Procedures for handling Complaints
  The procedures for the receipt, retention and treatment of a Complaint are set out below and shall be fully complied with.
5.2
Submission of Complaint
  Every Complaint shall be reported in person or in writing. The complainant should provide his particulars as follows:
  - Name;
  - Department/Company;
  - Contact Number and Email if available.
  This policy requires complainants to put their names to allegations because appropriate follow-up questions and investigations may not be possible unless the source of the information is identified.
5.3
Review and Investigation of Complaint
  Upon receipt of any Complaint, the AC shall:
5.3.1 determine whether the Complaint falls within the scope of this policy;
5.3.2 appoint an investigator with no personal interest in the matter to conduct an investigation into the matters disclosed, if they determine it to be necessary or appropriate;
5.3.3 inform complainant of the likely timeline for a final response;
5.3.4 recommend any remedial or legal action to be taken, where necessary; and
5.3.5 notify complainant of actions taken or reason(s) should it be decided that no action is to be taken.
5.4 Registration of Complaints
  The AC shall maintain or caused to be maintained a Complaints Register for the purposes of recording all Complaints received, the date of such Complaint and nature of such Complaint.
  The AC shall approve making the Complaints Register available for inspection upon any request by investigating authorities.

6.

FRIVOLOUS OR MALICIOUS COMPLAINTS

6.1 Any person who files a Complaint which is frivolous, in bad faith, in abuse of these policies and procedures, with malicious or mischievous intent will not be protected by this policy and may be subject to administrative and/or disciplinary action including but not limited to the termination of employment or other contract, as the case may be.

7.

CONSISTENCY WITH LAWS AND REGULATIONS

7.1 This policy shall be read in conjunction with any laws, regulations, rules, directives or guidelines that the Stock Exchange Securities Trading Limited (“SGX-ST”), the Companies Act and/or Securities and Future Act (“SFA”) may from time to time prescribe or issue on the receipt, retention and/or treatment of complaints regarding any matters governed by this policy.
7.2 In the event that any policy or procedure herein is inconsistent or in conflict with the laws, regulations, rules, directives or guidelines as prescribed by SGX-ST, the Companies Act and/or SFA or any part thereof, the laws, regulations, rules, directives or guidelines as prescribed by SGX-ST, Companies Act and/or SFA shall prevail to the extent of such inconsistency or conflict.

8.

DISSEMINATION OF POLICY

8.1
The Human Resource Department shall make available to all employees a copy of this policy.