WHISTLEBLOWING POLICY

1. Introduction

Golden Equator Capital Pte Ltd (“the Company”) is regulated by the Monetary Authority of Singapore, Singapore’s central bank and integrated financial regulator. The Company and its Board of Directors are fully committed to conducting business with integrity and the highest ethical standards while complying with the applicable laws and regulations.

In line with this commitment, this Whistleblowing Policy (“the Policy”) is established to ensure the necessary communication channels are available. This Policy is also aligned with the Company’s aim to cultivate a culture of Accountability, Integrity and Supportive community.

The Policy is to be read in conjunction with the Securities and Futures Act.

2. Objective and Scope

Anyone has the right to whistle blow. The Policy is applicable to all employees, vendors, associated stakeholders and clients of the Company.

The objective of the Policy is to:

Provide a trusted avenue for all parties mentioned above to report serious wrongdoing or raise concerns in relation to possible fraud, improper and unethical conduct without fear of reprisals when whistleblowing in good faith.

3. Key Principles

The Whistleblowing Policy of the Company is structured around three key principles: (i) the protection of confidentiality, (ii) the prevention of victimization and non-retaliation principle, and (iii) the protection of the accused person.

(i) Protection of confidentiality

Confidentially is the corner stone of the Policy. The recipient of the whistleblowing report and all others involved in the whistleblowing process will treat the information on a “need-to-know” basis. The identity of the whistleblower will not be revealed without first obtaining the whistleblower’s explicit consent, unless its disclosure is required in response to a valid court order or by the law. The whistleblower will be given prior notice before any such disclosure.

The Company encourages whistleblowers to disclose their identity or provide contact details when reporting a concern in order to facilitate any follow-up actions. Anonymous reporting is, nevertheless, a possibility.

(ii) Prevention of victimization and non-retaliation

The protection of whistleblowers is of paramount importance to the Company. The Company will ensure to the best of its ability that employees who have filed a report or raised their concerns via the whistleblowing communication channels in good faith will be appropriately protected from any negative impact such as harassment, retaliation, discrimination or other types of unfair treatment. Retaliation includes any adverse action taken inappropriately against the whistleblower such as demotion, firing, salary reduction, etc.

Appropriate measures will be taken against any employee who engages in retaliatory actions towards a whistleblower. Appropriate measures can take the form of disciplinary actions, including the possibility of dismissal.

A report is made in good faith if this individual has reasonable grounds to believe the information was true at the time of reporting. If you believe you have suffered adverse consequences as a result of making a whistle blowing report, please inform the receiving officers via the web form in section 4.1 who will arrange for an independent investigation into the matter.

(iii) Protection of the accused person

Similarly, for the person being accused of alleged impropriety, his/her employment rights and right to privacy will need to be carefully considered. The person who is the subject of an investigation may be informed about the cause if appropriate.

If the investigation finds no evidence that justifies the allegations on the accused person, the accused person should be protected from any negative impact. If the outcome of the investigation validates the whistleblower’s concern and corrective measures are taken, the accused person should be protected from unintended or disproportionate negative effects that go beyond the objective of the corrective measures.

4. Reporting Procedures

Reports on any improprieties made in good faith should be in writing with the following information:

  • Details of the party(ies) involved
  • Date/period of incident
  • Type of concern
  • Evidence substantiating the report (where it is not possible, please provide a paragraph with as much details as possible supporting the report)
  • Contact details (in case further information is required)

4.1 Communication Channels

Reports can be made via any of the communication channels below. The receiving officers of the report are: Group COO and/or Head of People Experience Management.

Email: whistleblowing@goldenequator.com

OR

You may mail your report to the following address:

Golden Equator Capital Pte Ltd
Attn: (Group COO/Head of People Experience Management)
3 Fraser Street #05-28 DUO Tower
Singapore 189352

4.2 Handling of Whistleblowing Reports

All concerns raised will be presented to the Board of Directors and the Board of Directors will decide on who will lead the investigation. The lead of the investigation may at his or her discretion form a team comprising of a group of employees perceived to be independent for the purpose of conducting a detailed investigation of the report.

The outcome of the investigation will be presented to the Board of Directors, who will then make a collective decision on corrective measures to take, if applicable. The whole process shall be documented in a written report and kept by the Receiving Officers for a minimum period of 5 years.

In the case where the whistleblower reveals their identity or leaves their contact information, the Company will acknowledge receipt of their report in writing within a reasonable period after the report is received. If appropriate, the Company will endeavor to keep the whistleblower informed of the progress and outcome of the investigation.

5. Alternative External Reporting Channel

The Company encourages direct reporting of any suspected improprieties to the Company through its whistleblowing channels as the Company is responsible for investigations into the reported improprieties.

In the event that the whistleblower is not satisfied of the outcome of the Company’s investigation and would like to make a report to an external party, the individual may do so via the Online Feedback Form on the Monetary Authority of Singapore’s website:

Receiving Party: Monetary Authority of Singapore
Online Feedback form: https://eservices.mas.gov.sg/consumerfeedback/