This Whistleblowing Policy is intended to encourage and provides a confidential platform that enables employees to raise serious concerns internally in order that the Company can address and correct inappropriate conduct and actions. It is the responsibility of all Board Members, Board Committee Members, Officers, employees as well as volunteers to report concerns about violations of the Company ethics and code of conduct, or suspected violation of law or regulations that govern its operations.

Definition
The word whistleblowing refers to a situation where a person (internal or external) raising or reporting concerns at an early stage about an ongoing or suspected wrongful activities or wrongdoing within OIO Holdings Limited (“the Company”).

The person who raises or reports concern(s) of wrongful activities or wrongdoings within the Company is referred as “whistleblower”.

For the purpose of this Policy, the wrongful activities or wrongdoings refers to any potential violations or concerns relating to any laws, rules, regulations, acts, ethics, integrity and business conduct, including any violations or concerns relating to malpractice, illegal, immoral, embezzlement and fraudulent activities which will affect the business and image of the Company.

 

Objective
To provide an avenue and a structured mechanism for a person to raise or report concerns at an early stage about an ongoing or suspected wrongful activities or wrongdoing within the Company and, to protect the values of integrity, transparency and accountability in where the Company conducts its business and affairs.

 

Scope of the Policy
This policy does not cover employee grievances. Employees should refer to the Grievance Handling Policy and procedures to lodge his concerns. When in doubt, an employee may approach his HOC/ HOD or HR Department to clarify his concern.

 

Policy Statement of the Company
The Policy of the Board is:

To encourage active and moral obligation to report wrongdoings

All employees and others are required to report any ongoing or suspected wrongful activities or wrongdoings at the earliest possible stage through the proper channel of reporting so that immediate action can be taken.

 

To use internal disclosure to report wrongdoings
As far as reasonable, internal disclosure is encouraged and used to avoid public crisis.

 

To protect the whistleblower
Where the disclosure is made in good faith, the whistleblower will be protected against victimisation or other adverse treatment.

 

To ensure appropriate and fair disciplinary actions
All actions taken against the alleged wrongdoers would be fair and without prejudice.

 

To require that an effective whistleblowing guideline be established and maintained by the Company, the Whistleblowing Policy must be sufficient to:

• Establish formal and robust Whistleblowing Policy;
• Prohibit legal sanctions for retaliatory action taken against the whistleblower;
• Establish timely, feedback, response and remedial and/or corrective action;
• Ensure that this policy is properly communicated to all employees;
• Establish procedures to maintain records confidentiality and retention; and
• Embed integrity, transparency and accountability within the business.

Principles
The Whistleblowing Policy is based on several key principles such as following:

• To establish a formal and written Guidelines to provide a transparent method of addressing issues relating to whistleblower, such as answering standard questions, providing information and offering explanations.
• To apply as a control measure to alert the Company’s Management to take the necessary remedial and/or corrective actions before a problem became a serious crisis.
• To communicate to all employees and others on what the Whistleblowing Policy and the key processes.
• To encourage and enable employees and others to be able to report irregularities in good faith within the Company prior to seeking resolution outside the Company and without having to fear that their action may have adverse consequences.
• To provide timely feedback and response.
• To verify the report incidents in the appropriate manner and, if the reports are confirmed, all necessary steps to identify appropriate remedies will be taken promptly.
• To ensure effective implementation of this Guideline. This will enhance the Company’s accountability in preserving its integrity and will be able to stand up to public scrutiny. This in turn enhances and builds credibility of our stakeholders.

The whistleblower is protected from retaliation or any recrimination that may arise as a result of reporting in good faith an ethics violation, a suspected violation of law, a complaint of discrimination or harassment, suspected fraud or misappropriation of funds, or violation of the Company rules and regulations. Above examples of possible violations as detailed in paragraph are not exhaustive.

The Committee and members from the relevant Departments are required to ensure that the investigation and the Whistleblower’s identity remain confidential at all times.

Employees may report any possible violation at:

To: Audit Committee Chairman (main contact person)
Email: s.chong@oio.sg
Mobile: +60 12-979 6188

OR

To: Audit Committee Member (alternate contact person)
Email: t@oio.sg
Mobile: +65 9048 6883

An independent committee comprising of members of the Audit Committee (i.e. Whistleblowing Committee or “the Committee”) will review the complaint and establish the nature of the suspected violation. Investigations shall be conducted by the Committee or appointed person(s) by the Committee. The Committee shall update the Board during the course of the investigation.

The whistleblower shall provide details of the suspected violation, together with documentary proof if any. The lack of evidence should not deter an employee from reporting his concern if he is acting in good faith.

Upon receiving a report of a possible violation, the Committee shall respond to the whistleblower and if more information is required, the Committee will request to meet the whistleblower in a private meeting to establish the facts of the case.

If the nature of the report is a grievance rather than a possible violation of the Company’s rules and regulations, ethics or applicable law, the Committee shall direct the complaint to HR Department for follow-up and resolution.

Anonymous complaints may not be investigated as it curtails the investigation process and impedes the suspected violator from receiving fair and impartial treatment since the Committee is not able to establish the facts with the whistleblower. This, however, does not imply that all anonymous complaints will not be investigated.

Upon the conclusion of the investigation, the whistleblower and the Board shall be informed of the outcome. Any employee found to have made any baseless or malicious complaint deliberately and with intent to damage the reputation of another employee may be subject to disciplinary action.