Whistleblowing

Policy

Document Control Human Resources

Effective April 2016

Version 1.4 updated December 2021

Table of Contents

1. Overview........................................................................................................................................ 1
2. Scope of Policy ............................................................................................................................. 1
3. Definitions ...................................................................................................................................... 1
4. Responsibility ................................................................................................................................. 1
5. Whistleblowing Channel .............................................................................................................. 2
5.1 Investigation ......................................................................................................................... 2
5.2 Access and retention of Complaints Records ................................................................. 3

DeClout Whistleblowing Policy

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1. Overview

This policy aims to

a) provide a reliable avenue to report any suspected violation of DeClout Group, collectively
“the Company” or the “the Companies”. Code of Conduct or any applicable law or policy
without fear of reprisals when whistleblowing in good faith; and,

b) ensure that arrangements are in place to facilitate independent investigation of the

reported concern and for appropriate follow up actions to be taken.

For purpose of good corporate governance, it is the policy of the Company that any employee or
external third parties, such as suppliers, customers, contractors and other stakeholders of the
Company shall be free, without fear of retaliation, to make known or raise concerns about actual
or possible improprieties.

2. Scope of Policy

The main scope of whistleblowing policy covers:

a) Bribery & Corruption, fraudulent account, embezzlement and anti-trust / competition

b) Theft and misuse of company assets
c) Conflict of Interest, personal data privacy, employment relations and other inappropriate
behaviours
d) Retaliatory actions, securities violation and others
e) Unsafe work practices
f) Material breaches of Group policy
g) Violations of laws and regulations (including those that expose the company or its agents
to regulatory or criminal actions. e.g. securities frauds)
h) Any other matters involving fraud, corruption and employee misconduct

3. Definitions

The appointed Company Whistleblowing Committee comprises of

a) Managing Director, Exeo Global Pte Ltd

b) Group Chief Executive Officer, DeClout Pte Ltd
c) Director, Human Resources, DeClout Pte Ltd

4. Responsibility

It is the responsibility of the appointed Committee responsibility to ensure that the Company has
appropriate procedures for the receipt, retention and treatment of disclosures or complaints about
the Company’s accounting, internal accounting controls or auditing matters.

In addition, the Committee must protect the identity of the complainant and the complainant
should not suffer any retaliation for the disclosure or complaint made.

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All reported concerns are treated seriously and will direct resources towards investigation and
monitoring of the cases. The Company does not wish for any employee to misuse the channel for
personal gains, mere expressions of grievances and frivolous and malicious whistleblowing. If the
results of the investigation show the Employee has acted maliciously in reporting his/her concern,
he/she will be subject to disciplinary action up to and including termination of employment.

Company does not tolerate the harassment or victimization of anyone who reports a concern in
good faith. Anyone who engaged in retaliation against someone who reports a concern will face
disciplinary action, up to and including termination, regardless of that person’s position or stature
within the Company.

5. Whistleblowing Channel

In view of the protection afforded to an employee or any external third parties raising a bona fide
concern, it is preferable that the individual put his name and contact details in confidence rather
than anonymously and should provide the following details to assist in assessing the credibility of
the allegations:

a) Your name and contact details

b) Your relationship with the Company
c) Name of the people and/or companies involved
d) Details of what happened, where and when did it occur
e) Whether management has been notified (if so, whom)
f) How you got to know of the incident
g) Provide supporting evidence

The identity of the complainant will be kept confidential, with disclosure on a need-to-know basis.

Company has appointed Tricor CNP Corporate Services Pte Ltd to receive complaints.
Complainant can report his/ her concern by an email submission to appointed Company Secretary
via email address wei.hsiung.lee@sg.tricorglobal.com

5.1 Investigation

Company Secretary shall inform the Committee members of all Complaints received. All matters
reported will be reviewed within a reasonable timeframe, and after due consideration and inquiry,
a decision will be taken on whether to proceed with a detailed investigation.

If the Committee deems it appropriate to proceed with a detailed investigation, an investigation

team may be appointed to conduct investigation into suspected violation of Code of Conduct or
any applicable law or policy.

Depending on the nature of the reported concern and subject matter expertise required,
Committee may staff the investigation team with individuals from different functions to assist with
certain elements of the investigation or the whole investigation process.

If the Committee deems it appropriate, it may engage at the Company’s expense, independent
advisers, outside counsel or accountants unaffiliated with the Company’s auditors.

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Employees who are interviewed or asked to provide information have a duty to fully cooperate
with the investigation team, refrain from making speculations, discussing or disclosing matters
concerning the investigations.

Following investigation and evaluation of a Complaint, the Investigation Team shall report to the
Committee on recommended disciplinary action up to an including termination of employment or
remedial action, if any shall be communicated to the respective person or business unit.

5.2 Access and retention of Complaints Records

Any investigation reports, details and resulting actions are considered privileged and highly
confidential information. Access to such information restricted to the appointed Whistleblowing
Committee.

Records pertaining to the Complaint and the investigation, if any, shall be the property of the
Company and shall be retained by the Company in compliance with applicable laws and the
document retention policies of the Company.

The records shall be subject to safeguards to ensure their confidentiality and when applicable, to
protect the identity of the complainant.

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