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Whistle Blowing Policy

SCOPE OF POLICY APPLICATION AND RESPONSIBILITY FOR ITS MAINTENANCE

This policy applies to all employees of Keong Hong Holdings Limited (“the Company”), including full-time, part-time and contract employees and those of its local and overseas subsidiaries, and associates (the "Group").

The Audit Committee shall be responsible for the maintenance, regular review and updating of this policy. Revisions, amendments and alterations to this policy can only be implemented after approval by the Audit Committee and the Board of Directors. Changes will be notified in writing to all employees when these occur. 

PURPOSE

  1. This policy aims to provide an avenue for employees to raise concerns about wrongdoing, malpractice or Improper Accounting Activity within the Company and the Group which they may become aware of and to provide reassurance that they will be protected from reprisals, victimization or any Retaliatory Action for whistle-blowing made in good faith and without malice.

  2. "Retaliatory Action" means the use of (or any attempt to use) authority, threats or other action including but not limited to demotion, suspension, harassment or any other discriminatory action by any employee or officer of the Company/Group to influence or to interfere with the right of another employee to report any wrongdoing, malpractice or Improper Accounting Activity or against an employee who has, in good faith made or assisted in making a report of wrongdoing, malpractice or Improper Accounting Activity.

  3. This policy is intended to cover all concerns that could have an adverse impact on the Company or the Group, or both, such as actions that:-
    • may lead to incorrect financial reporting;
    • are unlawful;
    • are not in line with a legal obligation of a Company or Group policy or both;
    • may pose danger to the health and safety of an individual;
    • may damage or cause potential damage to the environment;
    • amount to professional or ethical malpractice;
    • deliberately conceal serious wrongdoings or malpractices;
    • may pose serious breach of fundamental internal control;
    • otherwise amount to serious improper conduct;
    • deliberately conceal information tending to show any of the above;
    • abuse of Authority for Personal Gain; or
    • any conflict of interest in any activity that is, or appears to be, opposed to the best interest of the Company.
    The above list is not exhaustive.

  4. Some examples of "Improper Accounting Activity" are:
    • Actual or suspected fraud, including deliberate errors in preparing evaluation or review of any financial statements of the Company or the Group or both ;
    • Actual or suspected error, including deliberate error in recording and maintenance of the financial records of the Company or the Group or both;
    • Actual or suspected deficiencies in or non-compliance with the Group's internal controls and procedures; and
    • Actual or suspected misrepresentation by an officer or auditors regarding a matter contained or required to be contained in the Company or the Group or both's financial records, reports or audit reports.
    The above list is not exhaustive.

POLICY

The Company is committed to the highest standards of ethical and legal business conduct.  In line with this commitment and the Company's commitment to open communication and strong corporate governance, this policy provides an avenue for employees to raise concerns about wrongdoing, malpractice or Improper Accounting Activity within the Company or the Group when they become aware and ensure that:

  1. independent investigations are carried out in an appropriate and timely manner,
  2. appropriate action is taken to correct the weaknesses in internal controls and policies which allowed the perpetration of fraud or misconduct or both, and to prevent a recurrence, and
  3. administrative, disciplinary, civil or criminal actions or any combinations of these are initiated following the completion of investigations are appropriately balanced and fair, while providing reassurance that complainants will be protected from reprisals or victimization for whistle-blowing in good faith and without malice.

All employees within the Company and the Group are encouraged to report any wrongdoing, malpractice or Improper Accounting Activity that they reasonably believe have taken place, is taking place or will take place, to the organisation appointed by the Company to receive such reports. The contact details of the organization are set out in the Procedures below. Such reporting is commonly known as "Whistle Blowing".

SAFEGUARD

Safeguards to be provided in the implementation of this policy are as follows:

(a) No Harassment, Victimization or Retaliatory Act

Harassment, victimization of or Retaliatory Action against the complainant will not be tolerated and appropriate steps will be taken to ensure the complainant suffers no detriment or retaliation as a result of raising concerns in accordance with this policy.

(b) Confidentiality

Every effort will be made to protect the complainant's identity, if so requested, so long as it is compatible with a proper investigation. However, it is important to be aware that it may be necessary to reveal the identity of the complainant, to assist in investigations under certain circumstances or where the Company or the Group is required by law to make sure disclosure.

PROCEDURES

  1. Procedures for handling Complaints

    The procedures for the receipt, retention and treatment of a Complaint are set out below and shall be fully complied with.

  2. Submission of Complaints

    Every Complaint shall be made in person or in writing and shall lodge the Complaint to any one of the following independent directors:-

    Mr Steven Lim Jun Xiong
    c/o SG Trust (Asia) Ltd
    One Raffles Quay #35-01
    North Tower
    Singapore 048583
    Tel : 65 6303 3318
    Fax : 65 6222 1416
    Email : steven.lim@sgprivasia.com

    Mr Wong Meng Yeng
    c/o Alliance LLC
    One Phillip Street #03-01
    Singapore 048692
    Tel : 65 6220 9000
    Fax : 65 6557 0090
    Email :mengyeng.wong@alliancelawcorp.com

    Mr Chong Weng Hoe
    c/o TUV SUD PSB Pte Ltd
    1 Science Park Drive
    Singapore 118221
    Tel: 65 6885 1388
    Fax : 65 6773 7483
    Email : weng-hoe.chong@tuv.sud.psb.sg

    Mr Steven Lim is the Lead Independent Director and Chairman of the Audit Committee ("AC"). Both Mr Wong Meng Yeng and Mr Chong Weng Hoe are members of the Audit Committee and Independent Directors.

    The complainant must provide his/her particulars as follows:

    1. Name
    2. Department/Company
    3. Contact Number and Email Address if available.

    The Complaint will not be attended to if the above-mentioned particulars are not stated. This policy requires employees to put their names to allegations because appropriate follow-up questions and investigations may not be possible, unless the source of the information is identified.

  3. Confidentiality of Identity

    Complaints may be submitted anonymously. In order to aid the review and investigation of complaints, a complainant is encouraged to disclose his identity when submitting Complaints and the identity of a complainant, so disclosed, shall be kept strictly confidential save where:

    1. the identity of the complainant, in the opinion of the Company's Board is material to any investigation;
    2. it is required by law, order or direction of any court, regulatory body or stock exchange; or
    3. the Company's Board is of the opinion that it would be in the best interests of the Company or the Group to do so.

  4. Determination by the Audit Committee

    Upon receipt of any Complaint, the AC may:-

    1. conduct its own investigation or review;
    2. instruct the Internal Auditor to conduct further investigations or review;
    3. instruct the relevant management to take such remedial action as it deems appropriate;
    4. engage such third parties as the AC may determine, to take remedial, to commence or conduct further investigations or review, as deem appropriate;
    5. report the matter to the authorities if there is reason to believe that a crime has been committed; and/or
    6. take any other action as the AC may determine in the best interests of the Group.

  5. Review and Investigation of Complaint

    In the event that the AC conducts its own investigation or review, the AC shall:-

    1. review and investigate the Complaint;
    2. inform complainant of the likely timeline for a final response;
    3. recommend any remedial or legal action to be taken, where necessary; and
    4. notify complainant of actions taken or reason(s) should it be decided that no action is to be taken.

  6. Abuse of Policies and Procedures

    All Complaints should be made in good faith with reasonable grounds for believing that a wrongdoing, malpractice or an Improper Accounting Activity has taken place, is taking place or will take place. Only upon the determination of the Audit Committee, may any action be taken against any employee who has made a complaint frivolously, maliciously, in bad faith, for personal gain, making an allegation knowing it to be untrue or unfounded, or otherwise an abuse of the policies and procedures herein. Company reserves the right to take such action as the Audit Committee deems appropriate against any such employee including but not limited to disciplinary action.

REVIEW OF POLICY

The Audit Committee shall review this policy on a regular basis and recommend any amendment as appropriate for approval by the Board of Directors.