Whistleblowing Policy

Purpose

PropNex Limited is committed to maintaining high standards of accountability and corporate governance.

PropNex and its subsidiaries (“the Group”) does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff in the course of their work.  This Whistleblowing Policy (the “Policy”) is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences.

Employees and outside parties, such as suppliers, customers, contractors and other stakeholders, may use the procedures set out in the Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, insider trading, collusion with competitors, serious breaches of Group policy, unsafe work practices or any other matters involving fraud, corruption and employee misconduct.

The Policy allows for reporting by employees or outside parties of such matters to the Compliance Department of the Group, without fear of reprisal, discrimination or adverse consequences, and also permits the Group to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.

The Policy is meant to protect genuine whistleblowers from any unfair treatment as a result of their report. Frivolous and bogus complaints will be disregarded. The Policy is also not a route for taking up personal grievances. These should continue to be taken up directly with Division or Department heads.

Reporting Mechanism

The Group encourages employees and outside parties to put their names to their allegations whenever possible.  Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided.  All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.

Concerns may be raised verbally or in writing.  As it is essential for the Group to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible.  The complaint should include details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible, and contact details, in case further information is required. The Receiving Officer is the Compliance Department. The contact details of the Receiving Officer are as follows:

Address: 480 Lorong 8 Toa Payoh #18-01 HDB Hub East Wing, Singapore 310480 (Compliance Department)
Hotline: 6829-6610
Email: whistleblowing@propnex.com

Complaints raised to other parties within the Group will be directed to the Receiving Officer, who is responsible for maintaining a centralized repository of all reported cases and ensuring that issues raised are properly resolved. All matters reported will be reviewed within a reasonable timeframe, and after due consideration and inquiry, a decision will be taken on whether to proceed with a detailed investigation.  Where necessary, guidance/direction may be sought from the CEO and/or other appropriate parties. 

The Receiving Officer submits whistleblowing complaints alleging irregularities to the CEO. Feedback on operational matters are forwarded to the respective division/ department heads for their follow-up. Complaints involving allegations of fraud and breaches of corporate governance will be submitted to the Chairman of the Board of PropNex.  In addition, where the complaints relate to a senior executive and/or the CEO, the Receiving Officer will escalate these to the Audit Committee, which will then decide whether to report the matter to the Board.

All complaints received by the Receiving Officer are submitted to the Audit Committee for information. 

The whistleblower email and hotline are for reporting irregularities such as -

  • Fraud, bribery, or corruption;
  • Misappropriation of funds, classified documents or assets;
  • Intentional error in the preparation, review or audit of any financial statement of the Group, falsification of or alteration to documents or accounts;
  • Failure to comply with laws and regulations applicable to the Group and related to accounting, internal accounting controls or auditing matters;
  • Criminal and dishonest acts, including theft, forgery, money laundering, violence or threatened violence, or criminal damage against property – detrimental actions taken in reprisal against a whistleblower;
  • Unlawful or unethical conduct that is in breach of any policies of the Group;
  • Danger of destruction to or unsafe practices in the work environment;
  • Abuse and misrepresentation of power and authority;
  • Discrimination on the basis of gender, race, or disabilities;
  • Harassment; and
  • Suppression or concealment of any information relating to any of the above actions.

Safeguards

The Group prohibits discrimination, retaliation or harassment of any kind against a whistleblower who submits a complaint or report in good faith. If a whistleblower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the CEO. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.

At the appropriate time, the individual making the report/complaint may need to come forward as a witness. If an employee or outside party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. However, the Group will not hesitate to take action against those who intentionally or maliciously give false or misleading information against someone else.

Handling of complaints

The Receiving Officer, may, in consultation with the Board of Directors and/or senior management, direct the complaint to the division/department best placed to address it, or lead the investigation to ensure prompt and appropriate investigation and resolution.  All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

The Group reserves the right to refer any concerns or complaints to appropriate external regulatory authorities.  Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations.  Employees who fail to cooperate in an investigation and/or deliberately provide false information during an investigation shall be subject to strict disciplinary action which may include immediate dismissal.

If, at the conclusion of an investigation, the Group determines that a violation has occurred or the allegations are substantiated, effective remedial action(s) commensurate with the severity of the offence will be taken.

Modifications

This policy will be reviewed no less than twelve months, and the Group may modify this Policy to maintain compliance with applicable laws and regulations or accommodate organizational changes within the Group.