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WHISTLEBLOWING POLICY

Whistleblowing Policy

1. Scope

  • Fraudulent financial reporting
  • Misappropriation of assets
  • Bribery & Improper payment scheme
  • Material breaches of Company policy
  • Violations of laws & regulations
  • Unsafe work practices
  • Employee misconduct
  • Any other matters

2. Responsibility

         Audit Committee responsible for oversight and monitoring, with the support of the CFO.

3. Procedures for Whistleblowing

3.1 Submission of feedback/complaints
  1. Employees are free to bring complaints to the attention the Audit Committee either in person or via e-mail to whistleblow@gssenergy.com.sg.
  2. The Complainant must provide his particulars as follows:

    (a) Name;
    (b) Department/Company (if any);
    (c) Contact Number and Email Address if available.
  3. The Complaint may not be attended to if the above-mentioned particulars are not stated. This policy requires the reporting party to put their names to allegations because appropriate follow-up questions and investigations may not be possible unless the source of the information is identified.
  4. Such complaints shall be made in good faith and shall not be mere expressions of personal grievances or for purposes of personal gains.
  5. The identity of the complainant will be kept confidential and the complainant shall not suffer any retaliation for his/her complaint.
  6. The content of the feedback/complaints should include details of the parties involved, date/period concerned, nature of concern, substantiating evidence (if available) & contact details.
3.2 Investigation
  1. The recipient of the complaint shall inform the Audit Committee of all complaints received, with an initial assessment of the appropriate treatment of the matter
  2. All matters reported shall be reviewed within a reasonable time frame and a decision shall be taken on whether to proceed with a detailed investigation
  3. If the Audit Committee deems it necessary to proceed with an investigation, the Committee shall appoint an investigation team, headed by a senior management member (independent of the parties the complaint is directed at) and proceed with the investigation
  4. Alternatively, where the Audit Committee deem appropriate, it may engage external parties to carry out the investigation, at the Company's expense
  5. The investigation team shall report back its findings & evaluations to the Audit Committee, with a recommendation on the action to be taken, if any
  6. The Audit Committee shall review the report and recommendations and made an appropriate decision
  7. The decision shall be brought to the attention of the Board for authorisation and the appropriate members of the senior management for implementation
3.3 Records of Feedback/Complaints
  1. Records of the feedback/complaints shall be the property of the Company and shall be retained by the Company in accordance with the applicable law and company policies regarding retention of documents.
  2. The records shall be safeguarded to ensure confidentiality of the identity of the complainant & the complaint