Bribery and Corruption Prevention Policy The Manager adopts a strong stance against bribery and corruption. In addition to clear guidelines and procedures for the giving and receipt of corporate gifts and concessionary offers, all employees of the Manager are required to make a declaration on an annual basis where they pledge to uphold the Manager’s core values and not to engage in any corrupt or unethical practices. This serves as a reminder to all employees to maintain the highest standards of integrity in their work and business dealings. The Manager’s zero tolerance policy towards bribery and corruption extends to its business dealings with third parties. Pursuant to this policy, the Manager requires that certain agreements incorporate anti-bribery and anti-corruption provisions. Whistle-Blowing Policy A whistle-blowing policy and other procedures are put in place to provide employees of the Manager and parties who have dealings with the Manager with well defined, accessible and trusted channels to report suspected fraud, corruption, dishonest practices or other improprieties in the workplace, and for the independent investigation of any reported incidents and appropriate follow up action. The objective of the whistle-blowing policy is to encourage the reporting of such matters so that employees or external parties making any reports in good faith will be able to do so with the confidence that they will be treated fairly and, to the fullest extent possible, be protected from reprisal. The ARC is responsible for oversight and monitoring of whistleblowing report. To ensure the confidentiality and independence of the whistle-blowing process, an email address directly linked to ARC Chairman is specifically created for whistle-blower to report directly to ARC Chairman who will review the information reported and if need to, he will direct an independent investigation team to investigate the reported matter. All whistleblowing reports can be made via any of the following Channels: 1) Website: https://singapore.deloitte-halo.com/ecw-speakup/?Pg=makereport 2) Email Address: ecw-speakup@tipoffs.com.sg 3) Hotline: 800 492 2615 Identities of whistle-blower, participants of the investigations and the investigation subject(s) will be kept confidential. No person will be subject to any reprisal for having made a report in accordance with the policy or having participated in the investigation and any reprisal suffered may be reported directly to the ARC Chairman. Under the Whistle-Blowing Policy, upon receiving instruction from ARC Chairman, the Compliance Officer (“CO”) or the Internal Auditor (“IA”) of the Company (together the “Delegated Officer”) may assist the ARC for the administration, implementation and overseeing ongoing compliance with the said policy. The Delegated Officer(s) reports directly and independently to the ARC Chairman on all matters arising under the Whistle-Blowing Policy. The Whistle-Blowing Policy is available on the website of ECW and whistle-blowing parties are able to lodge their concerns via the channels mentioned above. There was no whistle-blowing report received for FY2024. Anti-Money Laundering and Countering the Financing of Terrorism Measures As a holder of a Capital Markets Services Licence issued by MAS, the Manager abides by the MAS’ guidelines on the prevention of money laundering and countering the financing of terrorism. Under these guidelines, the main obligations of the Manager are: (a) evaluation of risk; (b) customer due diligence; (c) suspicious transaction reporting; (d) record keeping; (e) employee screening and representative screening; and (f) training. ANNUAL REPORT 2024 63 CORPORATE GOVERNANCE
RkJQdWJsaXNoZXIy NTkwNzg=