Whistle-Blowing Policy

1. Policy Statement

The Group encourages all individuals to report any known or suspected ethical or legal violations to Management, so that appropriate actions can be taken promptly to address the matter and minimise the Group’s exposure to potential risks arising from employees circumventing or overriding internal controls and processes.

2. Board Statement

The Board, including the Audit and Risk Management Committee (“ARMC”), is committed to fostering a culture of integrity and maintaining high standards of openness and accountability in the Group’s business dealings and stakeholder communications. The Board encourages individuals with knowledge of wrongdoing or misconduct to raise such concerns rather than remain silent.

3. Objective

This policy reaffirms the Group’s commitment to good corporate governance by providing a framework for responsible and secure whistleblowing without fear of reprisal or adverse consequences.

It enables employees and external parties to report, in good faith, concerns relating to misconduct, irregularities, legal or ethical violations, or breaches of internal controls and processes, and allows the Group to take appropriate corrective or remedial action where necessary.

Frivolous, malicious, or unfounded complaints will not be entertained, and the policy is not intended to be used for personal grievances or abuse by disgruntled individuals.

4. Reportable Incidents

— fraud, corruption and bribery;
— theft or misappropriation of funds or assets;
— forgery or falsification of documents;
— misuse or unauthorised disclosure of confidential documents or information;
— breaches of the Personal Data Protection Act;
— abuse, misuse, or misrepresentation of power and authority;
— professional misconduct or ethical malpractice;
— discrimination or harassment on the basis of gender, race or disability;
— acts or omissions that may endanger the health or safety of others; or
— non-compliance with applicable laws, regulations or policies.

5. Reporting Channel

The Group encourages employees and external parties to disclose their identities when raising concerns, as this facilitates a more effective investigation process. Anonymous reports may nevertheless be considered, taking into account the seriousness and credibility of the allegations and the availability of supporting information. All reports received will be treated with strict confidence, and reasonable efforts will be made to protect the whistleblower’s identity.

Concerns may be raised verbally, via email, or in writing, and should include sufficient details and supporting evidence, where available, to facilitate proper assessment and investigation.

All complaints and concerns raised under this policy shall be submitted directly to the ARMC.
‍
Email: whistleblow@kin.net

Mail:
51 Tai Seng Avenue
#04-06, Pixel Red,
Singapore 533941
(to be marked “Private & Confidential” to the Audit & Risk Management Committee Chairman)

6. Review and Investigation

All reports received will be reviewed by the ARMC within a reasonable timeframe to determine whether a formal investigation is warranted. Depending on the nature and significance of the matter, the ARMC may assign the investigation to the appropriate party, establish an investigation committee, or refer the matter to external regulators, auditors, legal advisers, or other independent professionals where appropriate.

All investigations will be conducted confidentially, subject to applicable laws and regulations. Where necessary, the subject of the complaint may be informed of the allegations and given an opportunity to respond. Employees who fail to cooperate with investigations or knowingly provide false information may be subject to disciplinary action, including dismissal.

Where allegations are substantiated, the ARMC will ensure that appropriate remedial or disciplinary actions are taken, commensurate with the severity of the matter.

7. Confidentiality

Every effort will be made to protect the confidentiality of the complainant’s identity, except where disclosure is necessary for investigations, professional advice, compliance with applicable laws or regulatory requirements, where the ARMC determines that disclosure is in the best interests of the Group, where the complaint is found to be frivolous or made in bad faith, or where the complainant’s identity is already publicly known.

8. Abuse of Whistleblowing Process

Any person who submits a frivolous, malicious, or bad faith complaint, or otherwise abuses this policy, may be subject to legal, administrative, or disciplinary action, including termination of employment or contract, where applicable.