WHISTLEBLOWING POLICY

INTRODUCTION

This Whistleblowing Policy ensures that the Company complies to a high standard of compliance with accounting, financial reporting, internal controls and auditing requirements and any legislation relating thereto. In line with this commitment, this policy aims to provide an avenue for staff and external parties to raise concerns and offer them reassurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.

This policy applies to all staff as well as to all other external parties who have business relationships with Trybe. These parties include customers, suppliers, contractors, applicants for employment/internship, and the general public.

Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organisational malpractice by a person who has or has had privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing within or by Trybe that is within its ability to control.

REPORTABLE INCIDENTS

Below is a list of examples (though not exhaustive) of reportable incidents covered by this policy:

    • Concerns about Trybe’s accounting, internal controls, or auditing matters;
    • Impropriety, corruption, acts of fraud, theft and/misuse of Trybe’s properties, assets, or resources;
    • Conduct which is an offence or breach of law;
    • Serious conflict of interest without disclosure;
    • Breach of Trybe’s policies or code of conduct;
    • Concealing information about any of the above malpractice or misconduct;
    • Any other serious improper conduct that may cause financial or nonfinancial loss to Trybe or damage its reputation;
    • Committing acts of fraud or making fraudulent statements to the Board, supervisors, staff members of the public and government authorities;
    • Intention to mislead, deceive, coerce, or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of Trybe.

PROTECTION AGAINST REPRISAL AND CONFIDENTIALITY

When raising concern or providing information about an actual, suspected, or anticipated wrongdoing, in good faith; the individual, be it an employee or anyone else, shall be protected against any reprisal such as employment termination, retribution, or harassment.

However, Trybe will not condone any frivolous, mischievous or malicious allegations. Staff found making such frivolous, mischievous or malicious allegations, shall be subject to disciplinary action in accordance to the Human Resources Policy and/or Handbook on Staff Conduct & Discipline. Concern or information about an actual, suspected or anticipated wrongdoing as well as its source shall be treated with strictest confidence.

Exceptions to above include:

    • When Trybe is under legal obligation to disclose such information provided;
    • When the information is already in the public domain;
    • When the information is given in strict confidence to legal or auditing;
    • Professionals for the purpose of obtaining professional advice; and
    • When the information is given to the Police for criminal investigation.

Concerns or information provided anonymously will still be given due consideration by Trybe but will be investigated on their own merits.

PROCEDURES

Concerns may be raised with or information provided to:

The Audit Committee
Trybe Limited
Blk 479 Tampines Street 44
#01-241
Singapore 520479
Email: AuditCommittee@trybe.org

Such reports are preferably made in writing, either in the form of a letter or other form of electronic communications such as email or message, and in detail setting out the background and history of events as well as the reason(s) for concern.

Investigation and Assessment

Assessment of the concern or information shall be made with due consideration given to the following factors:

    • Seriousness of the issue raised;
    • Credibility of the concern or information; and
    • Likelihood of confirming the concern or information from the attributable sources

Depending on the nature of the concern raised or information provided, the investigation will be conducted, involving one or more of the following individuals or entities:

    • The Audit Committee
    • The External Auditor, and/or
    • The Singapore Police Force and/or Commercial Affairs Department.

The amount of contact between the whistleblower and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistleblower during the course of the investigation. When the investigation is completed, the investigating officer(s) will report the findings to the Audit Committee for its necessary action.