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 This email address is strictly for whistleblowing complaints only. For any feedbacks related to salespersons’ conduct, disputes with salespersons, or transaction-related matters, please send it to legal@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 -