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Whistle Blowing Policy

1. Objective

The Policy is to provide avenue for all employees of EC World Asset management Pte. Ltd. (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 and other persons (the Whistle Blower) to report in good faith of suspected Reportable Conduct (misconduct or criminal offence) 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 conduct is:

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

The Compliance Manager (who co-ordinates internal audit) is the Receiving Officer for the purposes of the Policy and is responsible for the administration, implementation and overseeing ongoing compliance with the Policy. He reports directly 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 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 Receiving Officer, once receiving a report, is required to promptly report to the ARC Chairman, notify the sender and acknowledge receipt of the report within 3 business days. A person may also make the report directly to the ARC Chairman. 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 are to be provided in writing via email to

4. Investigation

ARC Chairman will review the information disclosed and direct any investigation as he deems fit. 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 to the extent possible.

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 to the Receiving Officer or 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 Manager 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 shall become effective on 1 September 2016.