The purpose of this whistleblowing policy (“Policy“) is to:
    • support the values of the GHY group of companies (the “Group“);
    • ensure employees and any other relevant persons can raise concerns without fear of suffering retaliation; and
    • provide a transparent and confidential process for dealing with concerns.
      This Policy applies to any employee, contract staff, vendor, contractor, third parties, or applicants for employment, or member of the general public who notices, is aware of, or has any concerns about any actual or suspected wrongdoings committed by any GHY employee, contract staff, management, or contractor, who intends to register a complaint and/or lodge a report.

      In addition, this Policy explains (a) that persons making reports will be treated fairly and (to the extent that this is within the Group’s control) be protected from unfair retaliation or damaging action and (b) the investigation and management of persons who are the subjects of such reports.

      In addition to possible improprieties in matters of financial reporting, this policy also covers but is not limited to the following matters:
    • fraud;
    • corruption, bribery or blackmail;
    • criminal offences;
    • failure to comply with a legal or regulatory obligation;
    • harassment at workplace;
    • endangering the health and safety of an individual; and
    • concealment of any of the above.
  1. Whistleblowing Policy Statement
    The Group is committed to achieving and maintaining high standards in all its working practices, including behaviour at work and service to the public. Employees are expected to conduct themselves with integrity and impartiality, and the Group will not tolerate any form of inappropriate conduct.

    The Group will accept all whistleblowing reports of actual or suspected inappropriate conduct that are made in good faith and, subject to this Policy, will use all reasonable efforts to ensure that whistleblowers and persons involved are not subjected to unfair reprisal and/or detrimental action.

    This Policy is subject to review and will be updated from time to time to incorporate changes in best practices, and applicable laws and regulations.

  2. Confidentiality
    Subject to this Policy and applicable laws and regulations, the Group will use all reasonable efforts to ensure that all complaints received in compliance with this Policy, including the identity of the whistleblowers and other persons who have been called as witnesses or otherwise participated in the investigations and the information received, will be handled in strict confidence.

    The Group will use all reasonable efforts to ensure that any information relating to a complaint will only be disclosed on a “need to know” basis. The Group will also take reasonable steps to ensure that all such information will be properly secured.

    Where concerns are unable to be resolved without revealing the identity of the employee and any other persons raising the concern, the Group will enter into a discussion/ dialogue with the employee and any other persons concerned as to whether and how to proceed.

    • the disclosure of the identity of the whistleblower is required by applicable law, an order of a court of competent jurisdiction, or a recognised stock exchange or government department or agency
    • the investigation process requires the disclosure of the information source;
    • the information is publicly available; or
    • the information is given on a strictly confidential basis for the purpose of obtaining professional advice.

  3. Protection
    A genuine whistleblower who files a complaint in good faith shall not be discriminated, intimidated or harassed. The whistleblower is protected even if the allegations prove to be incorrect or unsubstantiated.

    However, if any false allegation is made intentionally for personal gain or other malicious intent, appropriate action may be taken against the whistleblower.

  4. Reporting Modes
    Complaints may be made verbally or in writing.

    The whistleblower should provide all critical information and details so that the matter can be assessed and investigated effectively. Details should include the parties involved, dates, nature of the incident or concern, how was the impropriety discovered, how long has it been happening, value involved, relevant evidence if any.

    The whistleblower is encouraged to provide his/her name and contact details to facilitate investigation. Anonymous complaints lacking sufficient information may not be entertained due to the practical difficulties in conducting effective investigation.

    All complaints shall be submitted to Mr. Rocky Wang at the following:
    • Complaints Mailing Address: 7 Straits View, Marina One East Tower Level 12 Singapore 018936
    • Complaints Secure Email: sg_whistleblow_ghy@pwc.com

  5. Treatment of complaints/reports
    Depending on the nature of the allegation:

    Senior management may be involved in providing direction and leadership in the investigation process.

    Where considered necessary, the matter may be referred to the external regulatory authorities.

    The perpetrator will be provided with relevant information to give him/her the opportunity to respond or explain the matter.

    The possible outcomes after filing a report include, but are not limited to:
    • Disciplinary action, including dismissal, of the employee responsible.
    • Warning to the whistleblower employee if the claim is found to be intentionally harmful or intended for personal gain.
    • Warning or termination of services of external wrongdoer.
    • Warning to an external whistleblower if the claim is found to be intentionally harmful and intended to serve personal ends.
    • No action if the allegation is proved to be unfounded, where made in good faith.
    Responsibilities of employees
    All employees shall report any actual or suspected inappropriate conduct in accordance with this Policy.

    All employees shall cooperate with any investigations under this Policy. All persons involved in an investigation must not discuss any aspect of the investigation (or of the fact of the investigation or their involvement) with anyone other than the investigator(s).

    Employees shall not engage in any activity that is, or could be perceived to constitute, unfair retaliation.

    Responsibilities of the Audit and Risk Management Committee
      The Audit and Risk Management Committee shall:
    • review complaints received and any matters arising therefrom or in connection therewith, and establish whether there is sufficient ground for further action;
    • recommend, if need be, procedures to be put in place to manage complaints received that require immediate or urgent action;
    • initiate investigations when required; and
    • review and report to the Board of Directors the results of the investigations and recommendations for corrective or remedial action, or (as the case may be) administrative or disciplinary action, to be taken.