Whistleblowing Policy

Policy Statement

The Whistle-blowing Policy supports the commitment of YCH Group Pte Ltd and its subsidiaries (YCH) to observe the highest standard of integrity and ethical behaviour. It is intended to help foster and maintain an environment where employees and outside parties, such as suppliers, customers, contractors and other stakeholders can report unethical and corrupt practices, in good faith, without the fear of retaliation. YCH conducts business based on the principles of R.I.S.E values of Reliability, Integrity, Sincerity and Enterprise. YCH does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff or suppliers in the course of their work.

This policy document is intended to provide a framework to promote responsible and secure Whistle-blowing without fear of adverse consequences and reprisal.

YCH’s internal control and operating procedures are intended to detect and to prevent or deter improper activities. However, even the best systems of controls cannot provide absolute safeguards against irregularities. YCH has the responsibility to investigate and report to appropriate parties, allegations of suspected improper activities and to take appropriate actions. Employees and stakeholders are encouraged to use guidance provided by this policy for reporting all allegations or suspected misconduct or improper activities.

Objectives of the Policy

The Whistle-blowing Policy has the following objectives:

1. To provide avenues for employees, suppliers, customers and contractors to raise concerns and suggest ways to handle these concerns.
2. To enable the Audit and Risk Committee (ARC) and management of YCH to be informed at an early stage about acts of misconduct.
3. To reassure whistleblowers that they will be protected from punishment or unfair treatment for disclosing concerns in good faith in accordance with this procedure.
4. To help foster a culture of openness, accountability and integrity.

Definitions

The following words as used in this document shall have the meaning ascribed here:

4.1 “this Document” means this Policy and Procedures.

4.2 “YCH” or “the Company” means YCH Group Pte Ltd and its Subsidiaries.

4.3 “Whistleblower” means a person or entity making a protected disclosure about improper or illegal activity(ies) is referred to as a whistleblower. Whistleblowers may be YCH employees, applicants for employment, vendors, contractors, customers or general public. The whistleblower’s role is as a reporting party. They are not, investigators or finders of fact, nor do they determine the appropriate corrective or remedial action that may be warranted.

4.4 “Good Faith” is evident when the report is made without malice or consideration of personal benefit and the whistleblower truly believes that the report is genuine and free of personal biases. The burden of proof does not lie on the whistleblower and to keep the investigation unbiased and impartial the whistleblower is not the investigator or fact finder. Good faith is lacking when the disclosure is known to be malicious or made for personal gain.

4.5 “Possible Improprieties” means any activity, breach of business conduct and ethics or omission by an employee of YCH or any concerns regarding accounting or auditing matters, internal controls or internal accounting controls and other operational matters that are questionable or not in accordance with generally accepted accounting practices or trade practices prescribed by YCH.

This policy is intended to cover serious concerns that could have an impact on the Company such as actions that:

i) May lead to incorrect financial reporting;
ii) Are unlawful;
iii) Are not in line with a legal obligation or a policy of YCH;
iv) May pose dangers to the health and safety of any individual;
v) May damage or cause potential damage to the environment;
vi) Amount to professional or ethical malpractices;
vii) Deliberately conceal serious wrongdoings or malpractices;
viii) May pose serious breach of fundamental internal controls;
ix) Otherwise amount to serious improper conduct; or
x) Deliberately conceal information tending to show any of the above.

4.6 “Obstructive Action” means the use or attempted use of force, authority, intimidation, threats, undue pressure or any other action or behavior by any employee which tends to or in fact does obstruct, influence or otherwise interferes with another employee’s exercise of his right to report any Possible Improprieties or which may discourage other employees from so doing in the future.

4.7 “Complaint or Report” means any complaint alleging either Possible Improprieties or Retaliatory Action.

4.8 “Retaliatory Action” means the use or attempted use of force, authority, intimidation, threats, undue pressure of any sort or any other negative or other inappropriate action, by any employee or officer of YCH, against any person who has filed a Complaint or Report.

4.9 “Complaints Register” means a register to record details of all Complaints or Reports lodged.

Whistleblowing Reporting and Communication Channels

This privacy policy was last updated on January 1, 2022.