Whistleblowing Policy & Procedures

APEX Group desires and aims to develop, promote and maintain high standards of corporate governance within the Group.

The following Whistleblowing Policy (“Policy”) is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences.

The Policy aims to provide an avenue for employees or external parties to raise concerns about possible improprieties and obstructive action within the Group which they become aware of and to provide assurance that they will be protected from reprisals or victimization for whistle-blowing in good faith and without malice.

This Policy is designed to support the Group’s values, ensure that employees and any other persons can raise concerns without fear of suffering retribution, and provide a transparent and confidential process for dealing with serious concerns.

It should be noted that local laws may apply and a whistleblower may wish to seek legal advice accordingly.

This Policy is intended to cover any concerns or complaints including but not limited to actions which:

— may lead to incorrect financial reporting;

— are unlawful;

— are fraudulent;

— are not in line with a legal obligation or a policy of the Group;

— may pose dangers to the health and safety of any individual;

— amount to professional or ethical malpractices;

— deliberately conceal serious wrongdoings or malpractices;

— may pose serious breach of fundamental internal controls;

— otherwise amount to serious improper conduct; and/or

— deliberately conceal information tending to show any of the above.

If you wish to make a report under this Policy, you should do so to the Head of Internal Audit. The channels of reporting to the Head of Internal Audit are as follows:

APEX Group encourages you to identify yourself when raising a concern or providing information. All concerns will be treated with strict confidentiality.

Exceptional circumstances under which information provided by you could or would not be treated with strictest confidentiality include:

1. where APEX Group is required by law, or by the order or directive of a court of law, regulatory body or by the MAS or such other body that has the jurisdiction and authority of the law to disclose information provided;
2. where the information is already in the public domain;
3. where the information is given on a strictly confidential basis to legal or auditing professionals for the purposes of obtaining professional advice; or
4. where the information is given to the police or other authorities for criminal investigation.

APEX Group may supplement or amend this Policy from time to time.