Whistle Blowing Policy
1. Objective
The Policy is to provide avenue for all employees of EC World Asset management Pte. Ltd. as the manager of EC World Real Estate Investment Trust (the “Manager”) to disclose any improper conduct, any breach or suspected breach of law or regulation that may adversely impact the Manager, shareholders, employees, investors or the public at large, in accordance with the procedures as provided for under this policy and to provide for the protection to employee who reports such allegations.
2. Scope and Definition
This Policy is designed to facilitate employees of the Manager and other persons (the “Whistle-Blower”) to report in good faith of suspected reportable conduct (misconduct or criminal offence) (“Reportable Conduct”) through internal channel or external mail by establishing a defined process, through which such reports may be made with confidence, that enable the Whistle-Blower to be treated fairly and to the extent possible, protected from reprisal.
Reportable conducts include:
- Dishonesty, including but not limited to theft or misuse of resources within the Manager
- Fraudulent activities
- Bribery and Corruption
- Illegal activities
- Unsafe work practices
- Other serious improper conducts
- Any other conduct which may cause financial or non-financial loss to the Manager or damage to the Manager's reputation
A person who files a report or provides evidence which he knows to be false, or without a reasonable belief in the truth and accuracy of such information, will not be protected by the Policy and may be subject to administrative and/or disciplinary action.
Similarly, a person may be subject to administrative and/or disciplinary action if he subjects
- a person who has made or intends to make a report in accordance with the Policy, or
- a person who was called as a witness, to any form of reprisal which would not have occurred if he did not intend to, or had not made the report or be a witness.
Audit and Risk Committee (“ARC”) is responsible for oversight and monitoring of whistleblowing.
For the purposes of the Policy, upon receiving instruction from ARC Chairman, the Compliance Officer (“CO”) or Internal Auditor (“IA”) of the Manager (together the “Delegated Officer") may assist the ARC for the administration, implementation and overseeing ongoing compliance with the Policy. Delegated Officer reports directly and independently to the ARC Chairman on all matters arising under the Policy.
3. Procedure to Report a Conduct
The Policy emphasizes that the role of the Whistle-Blower is as a reporting party, and that Whistle-Blowers are not to investigate, or determine the appropriate corrective or remedial actions that may be warranted. The Reportable Misconduct may be disclosed in writing, telephonically or in person. However, all reports are encouraged to be made in writing, so as to assure a clear understanding of the issues raised. The information disclosed should be as precise as possible so as to allow for proper assessment of the nature, extent and urgency of preliminary investigative procedures to be undertaken.
All whistleblowing reports maybe provided via any of these 3 Channels:
- Website: https://singapore.deloitte-halo.com/ecw-speakup/?Pg=makereport
- Email Address: ecw-speakup@tipoffs.com.sg
- Hotline: 800 492 2615
4. Investigation
ARC Chairman will review the information disclosed and direct any investigation as he deems fit. Such investigation will be an independent investigation team commissioned by ARC. The independent investigation team will be reporting to ARC directly and independently. All employees have a duty to cooperate with investigations initiated under the Policy.
5. Protection to Whistle-Blower
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. Any reprisal suffered may be reported directly to the ARC Chairman.
6. Anonymous Whistle-Blower
Any anonymous report will not be entertained. Any employee or other person who wish to make a report is required to disclose his/her identity to the ARC Chairman in order for the Manager to accord any necessary protection to him/her. However, the Manager reserves the right to investigate into any anonymous disclosure.
7. Notification
Upon the completion of the whistleblowing process and procedures, the Whistle Blower will be accorded the privilege to be notified on the outcome of the report.
8. Effective Date
This Policy was effective on 1 September 2016 and updated on 11 March 2022.