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

3. Procedures for Whistleblowing

3.1 Submission of feedback/complaints

1. Employees are free to bring complaints to the attention of the Group CFO either in person or via e-mail to saytiong@giken.com.sg
2. Where the complaints concerns the Group CFO, such complaints shall be brought to the attention of the Group CEO, at sydney@giken.com.sg
3. Alternatively, the employee can e-mail the complaints to the Audit Committee at AC@giken.com.sg
4. Such complaints shall be made in good faith and shall not be mere expression 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 deem 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 Investigating 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 and the appropriate members of the senior management for authorisation and 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