Whistleblowing Policy

1. Objectives

A culture of good governance, integrity, responsibility, and accountability is important to Mandai Wildlife Group (“The Group”).

The Whistleblowing Policy, which has the total support and commitment of our Board, Audit & Risk Committee (“ARC”) and the Senior Management, is put in place with this objective.

The Group requires all business units and departments to comply with all applicable laws and regulations and to maintain proper standards of business conduct. The Group does not tolerate any impropriety, intentional deception, statutory non-compliance, wrongdoing or malpractice by staff and business partners in the course of their work.

This policy aims to set out a framework and provide guidance on reporting misconduct and improper activities, protection of whistle blowers and confidentiality of reporting and the investigation process.

2. Scope

The Whistleblowing Policy provides a formalised, secured and confidential avenue for both staff and external parties (i.e. suppliers, guests, and contractors) to raise concerns about actual or suspected improprieties on the part of Management or fellow employees and in so doing deter wrongdoing and promote standards of ethical behaviour and integrity in the work environment and in our dealings with external parties.

2.1 Reportable Incidents/Activities

Reportable incidents include and are not restricted to the following improper and unethical activities (actual or suspected):

Fraud is defined as wrongful or criminal deception intended to result in financial or personal gain. Below are non-exhaustive examples of the types of incidents that should be reported and escalated:

1. Fraud is defined as wrongful or criminal deception intended to result in financial or personal gain. Below are non-exhaustive examples of the types of incidents that should be reported and escalated:
   • Theft of cash
   • Pilferage of assets/stocks
   • Misappropriation of money
   • Embezzlement and financial irregularities
   • Falsification of official documents
   • Acceptance/receiving any form of gratification
   • Misrepresentation of the company
   • Misuse of company property
   • Failure to comply with any legal or regulatory guidelines Abuse of power or authority
   • Deliberate concealment relating to any of the above
2. Other improper activities which do not fall within the definition of fraud should also be reported. These activities are defined as irregular or not proper and usually indicates dishonest or malicious behaviour. Below are non-exhaustive examples of such activities:
   • Violations of company policies
   • Racial or sexual harassment
   • Threats to health or safety of any individual

2.2 Reporting Mechanism

1. Staff and external parties (i.e. suppliers, guests, and contractors) are encouraged to raise genuine concerns or suspicion of fraud or other improper activities at the earliest practical stage so that timely and appropriate actions will be taken.
2. We take whistleblowing seriously and your concern matters to us. It is encouraged that disclosures are made in writing to assure a clear understanding of the concerns raised. Any disclosure can be made to the following receiving parties:

   Email

   [email protected]
   (The whistleblowing email will be routed to Chief Human Resources Officer (“CHRO”) and Vice President, Internal Audit (“VP, IA”))

   Postal

   80 Mandai Lake Road Singapore 729826
   (Marked “Highly Confidential”, Attention to Internal Audit Department, and sealed in an envelope)

3. Alternatively, the whistleblower may direct their concerns to the following:

   Vice President, Internal Audit
   Karen Tan
   Email: [email protected]

   Chief Human Resources Officer
   Marcus Heng
   Email: [email protected]

4. All reports received will be escalated to the Group Chief Executive Officer ("GCEO”) and Chief Financial Officer (“CFO”).
5. Reports alleging fraud and serious offences will be escalated to the Audit and Risk Committee (“ARC”).
6. In the event a report involves key leadership appointments or board members, the report will be escalated to the Chairman of ARC to seek guidance on independent party required to carry out the investigation.

2.3 Confidentiality and Protection

1. A whistleblower has the option to identify himself/herself or remain anonymous. While we can understand that some individuals may wish to remain anonymous, concerns expressed or information provided anonymously will be investigated on the basis of their merits. Vague or insufficient information can impede the investigation process and consequently allegations may not be pursued. We therefore encourage all whistleblowers to identify themselves to facilitate the investigation process.
2. All information disclosed as well as the identity of the informant will be protected and kept confidential but may, under circumstances (e.g. necessary for conducting the investigation, reporting to authorities, legal/statutory requirements), be disclosed on a need-to-know basis to relevant parties.
3. No person should be intimidated or restrained from reporting any impropriety. The Group does not condone any acts of reprisal against a whistleblower. A whistleblower who acts and makes disclosures in good faith will be protected against reprisals. Victimisation of the whistleblower is viewed seriously and will not be tolerated and anyone found guilty of this will be disciplined. In the event that a whistleblower is treated unfairly, he or she may raise a complaint to the Group CEO or the Chairman of ARC, in which a separate investigation may be conducted. The investigation team will consist of members who are not part of the initial whistleblowing investigation and will be decided by the Group CEO and the Chairman of ARC.
4. If, however, an allegation is made frivolously, mischievously, maliciously or for personal gain, disciplinary actions may be taken against the complainant to deter any abuse of the Whistleblowing Policy. Similarly, anyone who condones wrongdoing through wilful suppression or concealment of relevant information or interferes with the investigation may be disciplined.

3. Information To Be Provided

In making a report, please provide the following information, where possible:

• Name(s) of person(s) and/or organisation(s) involved
• Description of the incident, including:
  • Date
  • Time
  • Location
• Frequency of occurrence of the incident
• Details of any other witnesses
• Supporting evidence and/or documents
• Value of any money or assets involved
• Any other information that may substantiate the concern

4. Other Related Information

• Mandai Partnership Policy
• Supplier Code of Conduct