Introduction
*SCAPE supports a transparent workplace where employees have direct access to provide feedback to the Board on governance related matters. *SCAPE does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by any employee at all levels in the course of their work. *SCAPE is committed to a high standard of compliance and stringently work to uphold prevailing accounting, financial reporting, internal controls and auditing requirements.

Scope
This policy applies to all employees as well as to all external parties who have direct business relationships with *SCAPE, e.g. customers, suppliers, contractors, applicants for employment, participants of our programmes and the general public.

Definition

• Whistle blower: A whistle blower is an individual who submits in good faith a complaint or concern to *SCAPE regarding any improper or illegal conduct within *SCAPE.
• Good Faith: Good faith is evident when the report is made without malice or consideration of personal benefit. Good faith is lacking when the disclosure is known to be malicious or false.

Purpose
This policy allows employees and public to report without fear of reprisal, discrimination or adverse consequences. In turn, it permits the Organisation to address such feedback by taking appropriate action. It aims to promote high standards of corporate governance, transparency and upholds public and stakeholder trust. This Policy governs the reporting and investigating of observed or suspected improprieties for appropriate investigation when such a feedback is received.

Reportable Incidents
Below is a non-exhaustive list of examples of reportable incidents:

• Impropriety, corruption, acts of fraud, theft and/misuse of *SCAPE’s properties, assets, or resources;
• Conduct which is an offence or breach of law;
• Serious conflict of interest without disclosure;
• Breach of company policies or code of conduct;
• Concealing information about any of the above malpractice or misconduct;
• Any other serious improper conduct that may cause financial or non-financial loss to *SCAPE or damage its reputation;
• Unethical behaviour or practices, endangerment to public health and safety and negligence of duty.

Protection Against Reprisal and Confidentiality
*SCAPE will protect the privacy of any employee or public who reports the misconduct. When raising concern or providing information about an actual, suspected wrongdoing, done in good faith; the individual, regardless an employee or anyone else, shall be protected against any reprisal such as employment termination black listing for projects or harassment. While the Policy is meant to protect genuine whistle blowers from any unfair treatment as a result of their report, it strictly prohibits frivolous and false complaints. The organisation reserves the right to seek counsel and guidance from the Board to explore suitable follow-up against malicious actions and falsehood to discredit the organisation.

Confidentiality
*SCAPE encourages whistle blower to provide contact details when raising a concern or providing information. All concerns will be treated with strict confidentiality. Exceptional circumstances under which information provided could or would not be treated with strictest confidentiality include:

• Where *SCAPE is under a legal obligation to disclose information provided;
• Where the information is already in the public domain;
• Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; or
• Where the information is given to the Police or other authorities for criminal investigation.

In the event *SCAPE is faced with a circumstance not covered by the above, and where your identity is to be revealed, we will endeavour to consult with the complainant prior to the release of the personal information.

Procedures
Reporting

• Any person may report allegations of suspected serious misconduct or any breach or suspected breach of law or regulation that may adversely impact the Organisation.
• Individuals are recommended to self-identify, though it is not a requirement of the policy.
• Each feedback or complaint received would be treated with utmost confidentiality and urgency. The Chairman of the Board and Audit Sub-com would be immediately notified and an internal investigation would commence. Suspected acts of misconduct may be reported in writing by completing the attached form and submit to Chairman of the Board, or the Audit Subcommittee.

Chairman of the Board and/or *SCAPE Audit Subcommittee
Address:
2 Orchard Link #04-01
Singapore 237978

Investigating

• Committee member who receives a report will notify the whistle blower (if identified) and acknowledge receipt of the reported violation or suspected violation within 2 weeks.
• Committee members shall meet to discuss about the action/investigation on the reports received from whistle blowers. They may also exclude from its meeting any person deemed inappropriate, depending on the nature of the complaint.
• Committee members will ensure investigations are carried out using appropriate channels, resources and expertise. The matters raised may be:
  • investigated internally;
  • referred to the external auditor;
  • referred to appropriate law enforcement agencies; and/ or
  • investigated by an independent inquiry.
• Committee members will report to the Committee Chairman on a periodic basis about the reports received and actions taken. The Company reserves the right to make any decision based on the findings by the Committee.