Whistleblowing Policy

“Whistle Blowing” refers to a voluntary disclosure of individual or organisational malpractice by a person who has privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing or malpractice within or by Ascentis Private Limited (“Ascentis”) that is within its ability to control. There are two categories of whistle blowers namely:

• “Internal WhistleBlowers” refers to employees who are expected to report incidents of misconduct involving peer, supervisor/superior or top management staff to relevant reporting points.
• “External WhistleBlowers” refers to customers, suppliers, service providers and other members of the public who report wrongdoings of employees to the Whistle-Blow Team.

2. Purpose

The Policy aims to create a trusted avenue where employees, suppliers, service providers, customers and other stakeholders are able to raise concerns on misconduct, irregularities or malpractices, without fear of harassment and/or victimization and with an assurance that their concerns will be taken seriously and investigated, and the outcome duly communicated. It is intended to encourage staff and other relevant stakeholders to report unethical or illegal conduct. Policy objectives include:

• Provide a confidential channel for escalation of concerns without fear of reprisal;
• Ensure consistent and timely response to reported improprieties and awareness by whistle blowers of their options/rights;
• Serve as a means of preventing and deterring misconduct that may be contemplated;
• Promote a culture of openness, accountability, and integrity.

3. Scope

All employees, customers, suppliers, service providers and other members of the public are subject to this policy to ensure the highest standards of ethics, honesty, openness, and accountability in line with the Ascentis’ commitment to enhance good governance, transparency and safeguard the integrity of Ascentis.

4. Policy Statement

This Policy is intended to provide guidance to those who have major concerns over any wrongdoing within or by Ascentis relating to unlawful conduct, financial malpractice or dangers to the public and environment that has taken place or is likely to be committed. Specific examples could include (list is not exhaustive):

• Fraud, corruption, misconduct, or unsafe work practices – unacceptable, dishonest, unethical conduct or improper behaviour by team members entrusted with a position of authority resulting in personal gain.
• Harassment and abuse and misrepresentation of power and authority;
• Failure to comply with laws and regulations;
• Actions detrimental to health and safety or the environment;
• Discrimination based on gender, race, disabilities;
• Serious conflict of interest without disclosure;
• Breach of Ascentis’s policies or Code of Ethics; and
• Concealing information about any of the above malpractice or misconduct.

5. Policy Exclusion

Whilst the whistle blowing procedures allow anyone to report possible improprieties, it excludes employee grievances or disagreements which should be handled by Ascentis Human Resources Division.

6. Reporting Procedures

To ensure independence and objectivity, reporting can be done in writing to Whistle-Blow Team at the below contact channels:

Address: 3015 Ubi Road 1, #03-01, Singapore 408705
Email address: [email protected]

As a guide, any written statement should preferably contain the following information to facilitate proper assessment and urgency of investigative procedures:

• Your name, designation, and contact information;
• Name(s) of person(s) involved;
• Your relationship with the reported person(s);
• The specific concern
• The reason(s) for the concern
• The background and history of the concern, including relevant dates;
• Length of time the impropriety had been perpetuated;
• If the concern has been raised with anyone else, if so, with who;
• Physical evidence and any other information that may substantiate the incident.

Although you are not expected to prove beyond doubt the truth of an allegation, it will be necessary to demonstrate to the person contacted that there are sufficient grounds for real concerns.

7. Complaints Handling

• Ascentis reserves the right to refer any concerns or complaints to appropriate external regulatory authorities.
• All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.
• The Whistle-Blow Officer will make a preliminary assessment and where necessary, consult with senior management, before directing the complaints or concerns to the relevant department or appropriate regulatory body for investigation.
• Depending on the nature of the complaints or concerns, the subject of the complaint may be informed of the allegation and be given an opportunity to explain the matter. Team members who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.
• The company will take prompt actions to remediate any process or system gaps to prevent a future occurrence.

8. Record – Keeping and Reporting

The Whistle-Blow Team will maintain a log of all complaints and concerns, tracking their receipts, investigation, and resolution.