Dealings in Securities Each Director and the CEO of the Manager is to give notice to the Manager of his acquisition of ECW units or of changes in the number of units or, as the case may be, ECW units which he holds or in which he has an interest, within two business days after such acquisition or the occurrence of the event giving rise to changes in the number of the units or, as the case may be, ECW units which he holds or in which he has an interest. All dealings in the ECW units by the Manager’s Directors will be announced via SGXNet. The Manager has devised and adopted a securities dealing policy for the Manager’s officers and employees which applies the best practice recommendations in the Listing Rules. To this end, the Manager has issued guidelines to its Directors and employees which set out prohibitions against dealings in ECW Group’s securities: (i) while in possession of material unpublished price sensitive information; (ii) during two weeks immediately preceding, and up to the time of the announcement of, ECW’s financial results for each of the first three quarters of ECW’s financial year; and (iii) during one month immediately preceding, and up to the time of the announcement of, ECW’s financial results for the full financial year. Prior to the commencement of each relevant period, an email would be sent out to all Directors and employees of the Manager to inform them of the duration of the period. The Manager will also not deal in ECW Group’s securities during the same period. Directors and employees of the Manager are prohibited from dealing in securities of ECW Group if they are in possession of unpublished price sensitive information of ECW Group. As and when appropriate, they would be issued an advisory to refrain from dealing in ECW Group’s securities. Under the policy, Directors and employees of the Manager are discouraged to trade on short-term or speculative considerations. They are also prohibited from using any information with respect to other companies or entities obtained in the course of their employment in connection with securities transactions of such companies or entities. The Manager has complied with its securities dealing policy in accordance with listing Rule 1207(19). Notwithstanding the above, the trading of the units of ECW has been suspended on a voluntary basis pursuant to listing Rule 1302 since 30 August 2023. As announced on 13 September 2024, the SGX-ST has no objection to ECW’s application for an extension of time to 31 May 2025, subject to certain conditions and among which, to provide a resumption of trading proposal by 31 May 2025. (F) CODE OF BUSINESS CONDUCT The Manager adheres to ethical code of business conduct policies which deal with issues such as confidentiality, conduct and work discipline, corporate gifts and concessionary offers. Clear policies and guidelines on how to handle workplace harassment and grievances are also in place. The policies that the Manager has implemented aim to help to detect and prevent occupational fraud in mainly three ways as follow: (i) the Manager offers fair compensation packages, based on practices of pay-for-performance and promotion based on merit to its employees. The Manager also provides various healthcare subsidies and financial assistance schemes to alleviate the common financial pressures its employees face; (ii) documenting policies and work procedures incorporate internal controls which ensure that adequate checks and balances are in place. Periodic audits are also conducted to evaluate the efficacy of these internal controls; and (iii) the Manager seeks to build and maintain the right organisational culture through its core values, educating its employees on good business conduct and ethical values. EC WORLD REIT 62 CORPORATE GOVERNANCE
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