Whistle Blowing Policy

Preamble

The Group has in place whistle-blowing policies and arrangements by which staff of the Group and external parties such as the Group's business associates may, in confidence, raise concerns about possible corporate improprieties in matters of financial reporting or other matters to ensure independent investigation of such matters and for appropriate follow up actions. All whistle-blowing reports are to be sent to the Chairman of the Audit Committee, who coordinates independent investigations of such matters and for appropriate follow up action.

Reportable Incidents

The terms defalcation, misappropriation, and other fiscal irregularities refer to, but are not limited to, the following:

• Any dishonest or fraudulent act
• Misappropriation of funds, securities, supplies, or other assets
• Impropriety in the handling or reporting of money or financial transactions
• Profiteering as a result of insider knowledge of the Group’s activities
• Disclosing confidential and proprietary information to outside parties
• Disclosing to other persons securities activities engaged in or contemplated by the Group
• Accepting or seeking anything of material value from contractors, vendors, or persons providing services/materials to the Group which influences their judgement or conduct in a position of trust
• Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment
• Any similar or related irregularity

Confidentiality and Protection of Whistle Blower

The Chairman of the Audit Committee treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the Chairman of the Audit Committee immediately and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act (see REPORTING PROCEDURES section below).

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Group from potential civil liability.

Employees of the Group may not retaliate against a whistle-blower for reporting an activity which that person believes to be fraudulent or dishonest with the intent or effect of adversely affecting the terms or conditions of employment (including, but not limited to, threats of physical harm, dismissal, transfer to an undesirable job assignment, demotion, suspension, or impact on salary or wages). A whistle-blower is defined as an employee who informs a manager, supervisor, or Chairman of the Audit Committee about an activity which that person believes to be fraudulent or dishonest.

Whistle-blowers who believe that they have been retaliated against may file a written complaint with the Chairman of the Audit Committee. Any complaint of retaliation will be promptly investigated and appropriate remedial measures will be taken if allegations of retaliation are proven. This protection from retaliation is not intended to prohibit managers or supervisors from acting, including disciplinary action, in the usual scope of their duties and based on valid performance-related factors.

Reporting Procedures

Great care will be taken in the investigation of suspected improprieties or irregularities to avoid mistaken accusations or alerting suspected individuals that an investigation is under way.

An employee who discovers or suspects fraudulent activity will contact the Chairman of the Audit Committee immediately. The employee or other complainant may remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his attorney or representative, or any other inquirer should be directed to the Investigations Unit or the legal counsel, if any. No information concerning the status of an investigation will be given out. The proper response to any inquiries is: “I am not at liberty to discuss this matter.” Under no circumstances should any reference be made to “the allegation,” “the crime,” “the fraud,” “the forgery,” “the misappropriation,” or any other specific reference.

The reporting individual should be instructed to do the following:

• Do not contact the suspected individual to determine facts or demand restitution.
• Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Chairman of the Audit Committee or the legal counsel, if any.

The disclosure should contain as much detail as possible, including (not limited to):

• Name and contact details;
• Nature of the wrongful practice;
• Names of person(s) / company(ies) allegedly involved;
• Relationship with the alleged person(s) / company(ies);
• Names and contact details of any witnesses;
• Description of the incident (including date, time, location, how did the incident occur and the probable cause(s) of the incident);
• Duration of the incident, frequency of occurrence and when the incident was first noticed;
• Details of any physical or material evidences you know of; and
• The value of any money or asset involved (if this is relevant in the disclosure)

Contact Details of Chairman of the Audit Committee:
Name: Mr Kwong Choong Kuen
Email: ck@capkadvisory.com