THE MANAGERWhistle-Blowing

WHISTLE-BLOWING POLICY
  1. Introduction
    IREIT Global Group Pte. Ltd. (the “Company”), the manager of IREIT Global (and together with the subsidiaries of IREIT Global, the “Group”), has put in place a channel for employees and parties with whom the Group has business dealings with, to report, without fear of retaliation, discrimination or adverse consequences, any actual or suspected wrongdoing or improper conduct within the Group. The Audit and Risk Committee (“ARC”) has reviewed and approved the whistle-blowing policy and arrangements, and is responsible for ensuring that all whistle-blowing cases are independently investigated for appropriate follow-up act and action.
  2. Who should report?
    • Employees
    • Vendors/contractors
    • Consultants
    • Tenants
    • Vendors
    • Any other parties whom the Company, IREIT Global or the subsidiaries of IREIT Global (the “Group”) has business dealings with.
  3. What to report?
    Reportable complaints/concerns include and are not limited to the following activities (actual or suspected):
    • Financial malpractice or impropriety
    • Fraud or corruption or any dishonest act
    • Criminal activity including forgery or falsification of and alteration to the Company’s documents/accounts
    • Breach of legal obligation (including negligence, breach of contracts)
    • Any forms of harassment
    • Conflict of interest without disclosure
    • Abuse of power or authority
    • Danger of destruction to and unsafe practices in the work environment
    • Improper conduct or unethical behaviour (eg. disclosure of confidential and proprietary information to party(ies) without prior authorisation and a need-to-know basis; accepting/seeking anything of material value from business associates eg. vendors)
    • Attempts to conceal any of the above
    • Any other similar or related inappropriate conduct or activities that might lead to other damaging implications to the Group.
  4. How to report? The Company has engaged KPMG Services Pte. Ltd. (“KPMG”) to provide an independent platform for the reporting of complaints/concerns in good faith without fear of reprisal. All complaints/concerns should be reported in writing to the independent reporting channels as follows:
  5. Handling of whistle-blowing reports
    1. All reportable complaints/concerns received will be processed by KPMG, and routed directly to the Chairman of the ARC (“ARC Chairman”) via email. The ARC Chairman, with the ARC members and any advisers, if appropriate, shall decide whether to investigate the complaint/concern, and if so, to undertake the investigation accordingly. Consideration will be given to these factors:
      • Severity of the complaint/concern raised;
      • Credibility of the complaint/concern or information; and
      • Likelihood of confirming the complaint/concern or information from other sources.
    2. It is necessary for KPMG and the ARC Chairman to be given all vital information in order to be able to effectively and investigate any complaints/concerns. As such, all whistle-blowing reports received by KPMG should be as specific and detailed as possible. It should contain basic details such as the party(ies) involved, dates or period of time, the type of complaint/concern, evidence substantiating the complaint/concern, and contact details.
    3. Depending on the nature of the complaint/concern raised or information provided, the investigation conducted may involve one or more of these persons or entities:
      • The ARC;
      • The external and/or internal auditor;
      • Forensic professionals or private investigators; and
      • The police, Commercial Affairs Department or other authorities.
    4. If, at the conclusion of an investigation, it is determined that a violation has occurred or the allegations are substantiated, remedial action commensurate with the severity of the offence will be taken.
    5. Regardless of the significance of allegations or the outcome, all whistle-blowing reports will be tabled and discussed at the ARC meetings.
  6. Responding to whistle-blowing reports
    1. Within a reasonable timeframe, the ARC Chairman will write to the whistle-blower (directly or through KPMG) to:
      • Indicate how it proposes to deal with the complaint/concern;
      • Give an estimate of time it will take to provide a full response;
      • Inform whether any initial enquiries have been made;
      • Supply information on support available to the whistle-blower; and
      • Inform the whistle-blower if further investigations will take place and if not, to provide reasons.
  7. Anonymous reporting
    1. Anonymous reports are permitted but whistle-blowers are encouraged to provide their particulars. The investigation of complaints/concerns is facilitated by access to whistle-blowers for the purposes of obtaining further information and clarifications related to the complaint/concern.
    2. All whistle-blowers are expected to:
      • Act in good faith;
      • Have reasonable grounds; and
      • Not make the report for personal gain.
      Acting in good faith means without malicious intentions and in the best interest of the Group. If allegations are proven to be malicious, appropriate actions, including legal action and blacklisting, may be taken.
  8. Confidentiality of identity
    1. The identity of the whistle-blower will be kept confidential. Consent will be sought should there be a need to disclose the identity of the whistle-blower for investigation purposes, subject to the following circumstances:
      • Where there is a legal obligation to disclose information provided;
      • Where the information is already in the public domain;
      • Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; and
      • Where the information is given to the police or other authorities for criminal investigation.
    2. In the event the ARC is faced with a circumstance not covered by the above, and where the whistle-blower’s identity is to be revealed, it is the endeavour of the ARC to discuss this with the whistle-blower first.
  9. Process
    1. The report should be factual and contain as much information as possible to facilitate proper assessment and urgency of investigative procedures.
    2. During the course of investigation:
      • The whistle-blower and any party(ies) or personnel may be contacted for further information and/or any documents that can shed light on the investigation.
      • Great care, sensitivity and timeliness must be exercised whilst carrying out the investigation to avoid misleading or wrongful conclusions or actions which may affect the evidence of the investigation or result in wrongful accusations of any party(ies).
    3. Upon investigation:
      • Recommended actions will be initiated.
      • Investigation results are confidential and will not be disclosed or discussed with anyone other than those with a legitimate need to know. The whistle-blower will not be updated on the outcome of the investigations other than confirmation that the complaint/concern has been dealt with by the Company. This is to safeguard all parties, including the Company.
    4. In consideration of all whistleblowing activities, the ARC will then decide whether to report the complaint/concern to the Board of Directors.
    5. The ARC, and where appropriate the Board of Directors, are to review actions taken by the Company towards whistle-blowing initiatives and ensure that fraudulent practices are reviewed without prejudice or biasness, and executed with professional integrity in compliance with the Company’s policy.
  10. Immunity or protection from disciplinary action
    1. The Company encourages the reporting of any actual or suspected wrongdoing or improper conduct in good faith and in pursuit thereof, shall use its best endeavours to grant immunity or protection to whistle-blowers.
    2. A whistle-blower acting in good faith and who has not himself or herself engaged in such complaints/concerns shall be protected from any forms of harassment, retaliation, adverse employment or career advancement consequence or discrimination, including but not limited to demotion, dismissal or reduction of compensation or privileges of employment. An unsubstantiated complaint/concern may also be treated in good faith if there is no malicious intentions and in the interest of the Group.
    3. The Company will take the necessary steps to ensure that persons alleged of wrongdoing or improper conduct are fairly treated. These may include:
      • Providing assistance and support to such persons;
      • Keeping the fact that an investigation has been conducted, its results and the identities of such persons confidential (notably if the allegations are unsubstantiated); and
      • Informing such persons at an appropriate time that an investigation has been conducted and providing them the opportunity to respond to the allegations before concluding the investigations.

The Company reserves the right to modify the contents to maintain compliance with the applicable laws and regulations or accommodate organisational changes.

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