Corporate Governance and Whistleblowing Policy

Audit Committee:
1. Mr. Tam Hon Fai (Chairman)
2. Mr. Chan Kwok Wong Kelvin
3. Mr. Wong Ka Bo Jimmy

Remuneration Committee:
1. Mr. Chan Kwok Wong Kelvin (Chairman)
2. Mr. Koh Chew Chiang
3. Mr. Tam Hon Fai

Nomination Committee:
1. Mr. Poon Soon Huat (Chairman)
2. Mr. Chan Kwok Wing Kelvin
3. Mr. Wong Ka Bo Jimmy

GOVERNANCE

We believe that good governance practices are imperative in building a sound corporation with an ethical environment, thereby protecting the interests of all our stakeholders. We are devoted to continually enhance and add to our shareholders’ value through the maintenance of a high standard of corporate governance in our Group, and ensuring that all employees remain committed to comply at all levels.

We seek to uphold the highest standard of business ethics through our commitment to accountability and transparency to our stakeholders.

(a) Anti-Corruption

The Company’s fundamental values and capability to act with honesty and integrity will ultimately be subverted through fraud, bribery and corruption practices should it be allowed to occur. As such, the Company takes on a zero-tolerance approach towards bribery, fraud and corruption. We are committed to ensuring that all employees understand how to comply with fraud and anti-corruption rules and regulations.

(b) Business Conduct & Ethics

Code of Conduct & Conflict of Interest
In pursuit of conducting our business with integrity and honesty, all employees are expected to adhere to the Company’s Disclosures of Interest, Conflict of Interest Policy. Clear guidelines are also provided to both directors and employees in the Company’s Code of Conduct for Directors and Employees respectively.

In the Code of Conduct for Directors, emphasis is placed on potential conflict of interest, detailing the disclosure procedures should any material personal interest be present in a proposed transaction involving the Company and the relevant director. In the Code of Conduct for Employees, emphasis is placed on bribery scenarios to remind employees that receiving gifts in any form that are intended to influence a business decision are unacceptable. A list of misconduct examples is included, in particular, ‘soliciting or collecting contributions for any purpose at any time in the Group without the permission of Supervisor’ is explicitly specified.

Breaches of this Code of Conduct will result in disciplinary action up to and including termination of employment or dismissal.

Whistleblowing Policy
The Group’s whistleblowing policy encourages and provides a well-defined and accessible channel to stakeholders (i.e., both internal and external) of the Company to raise concerns over any unlawful conduct, financial malpractice and/or other wrong-doings. Under this policy, employees or any other persons may report suspected matters of wrongdoing affecting the Company.

Making a report
Incidents of actual or suspected fraud, corruption or other forms of unethical conduct should be promptly reported to following email: gary.koh@singtec.com.sg. In the event whereby any whistleblowing instances involves the appointed personnel, the report may be made directly to the Chairman of the Audit Committee at Michaeltam@marksmanhk.com.

Confidentiality
To the extent that it is lawful and the investigative process allows, all reports received, including the identity of the reporting party, will be handled in strict confidence. All disclosures will be treated in a confidential manner, protecting
the identity of the person that made the disclosure so as to encourage the reporting of any suspicious activities without fear of reprisal, victimization, harassment or discriminatory treatment.