THE MANAGERWhistle-Blowing

WHISTLE-BLOWING POLICY

1. Introduction
   IREIT Global Group Pte. Ltd. (the “Company”), the manager of IREIT Global, has put in place a channel to allow whistleblowing by all stakeholders to report, without fear of retaliation, discrimination or adverse consequences, on any concerns about illegal, unethical, unprofessional, unacceptable practice and misconduct, or otherwise inappropriate behaviour or activities that they may observe on its employees, officers and directors in the course of their work. The Audit and Risk Committee (“ARC”) has reviewed and approved the Whistleblowing Policy and arrangements, and is responsible for ensuring that all whistleblowing cases are independently investigated for appropriate follow-up act and action.
2. Who should report?
   
   • Employees
   • Vendors/contractors
   • Consultants
   • Tenants
   • Vendors
   • Unitholders
   • Any other parties whom the Company, IREIT Global or the subsidiaries of IREIT Global (the “Group”), has a relationship
3. What to report?
   Reportable 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 Company 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 (e.g., 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 e.g., 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 implemented a whistleblowing platform, Signalement, to provide an independent platform for the reporting of complaints/concerns in good faith without fear of reprisal. This platform is also used by Tikehau Capital¹. All complaints/concerns should be reported in writing to the independent reporting channel as follows:

   Online Form - https://tikehau-capital.signalement.net/lang/en/entreprises

5. Handling of whistle-blowing reports
   1. All whistleblowing reports received through the platform and/or by way of any other means will be processed by independent functions (i.e., Tikehau Compliance, Human Capital and Internal Audit). Reports will be raised to the ARC Chairman and members of the ARC. The ARC Chairman, with the ARC members, any advisers, and independent functions, 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 concern raised;
      • Credibility of the concern or information; and
      • Likelihood of confirming the concern or information from other sources.
   2. It is necessary for ARC Chairman to be given all vital information in order to be able to understand and investigate any complaints/concerns. As such, whistleblowing reports 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 (where provided).
   3. Depending on the nature of the 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;
      • External legal counsel;
      • 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 whistleblowing reports will be tabled and discussed at ARC meetings.
6. Responding to whistle-blowing reports
   1. The whistleblower will receive an immediate automated acknowledgement when a report is submitted through the platform.
   2. Within a reasonable timeframe, the case manager from Compliance, Human Capital or Internal Audit, on behalf of the ARC Chairman will write to the whistleblower (directly or through the platform Signalement) to, where possible:
      • Indicate how it proposes to deal with the concern;
      • Give an estimate of time it will take to provide a full response;
      • Advise whether any initial enquiries have been made;
      • Supply information on support available to the whistleblower; and
      • Inform the whistleblower if further investigations will take place and if not, to provide reasons.
7. Anonymous reporting
   1. Anonymous reports are permitted but whistleblowers are encouraged to provide their contact details. Signalement offers the ability to report anonymously and use a confidential code to access the platform to receive further updates. The investigation of complaints/concerns is facilitated by access to whistleblowers 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 whistleblower will be kept confidential. Consent will be sought should there be a need to disclose the identity of the whistleblower 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 whistleblower’s identity is to be revealed, it is the endeavour of the ARC to discuss this with the whistleblower first.
9. Process
   1. All reports 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 whistleblower 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 whistleblower may or may not be updated on the outcome of the investigations beyond confirmation that the 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 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 whistleblowing initiatives and ensure that fraudulent practices are reviewed without prejudice or bias, 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 whistleblowers.
    2. A whistleblower acting in good faith 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 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 of this policy to maintain compliance with the applicable laws and regulations or accommodate organisational changes.