CytoMed Therapeutics Limited and its subsidiaries (the "Group") are committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements, and any legislation relating thereto. In line with this commitment, the Whistleblowing Policy (the "Policy") aims to provide an avenue for employees and external parties to raise concerns and offer reassurance that they will be protected from reprisals or victimisation for whistle blowing in good faith.
The Policy is intended to encourage employees and external parties to raise concerns, in confidence, about possible irregularities.
This Policy applies to all employees as well as to shareholders, consultants, vendors, contractors, outside agencies doing business with employees of such agencies, and any other parties with a business relationship with the Group.
Deter wrongdoing and to promote standards of good corporate practices.
Provision of proper avenues for employees and external parties to raise concerns about actual or suspected improprieties in matters of financial reporting or other matters and receive feedback on any action taken.
Give employees and external parties the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
Some examples of concerns covered by this Policy include, but are not limited to, the following:
The above list is intended to give an indication of the kind of conduct which might be considered as "wrong-doing". In cases of doubt, the whistle-blower should seek to speak to his or her immediate superior or follow the procedure for reporting under this Policy.
If an employee raises a genuine concern under this Policy, he or she will not be at risk of losing his or her job or suffering from retribution or harassment as a result. Provided that the employee is acting in good faith, it does not matter if he or she is mistaken. For an external party who raises genuine concern in good faith, he or she will not be barred from future quotation or tenders of jobs/services in the event he or she is mistaken.
However, the Group does not condone frivolous, mischievous or malicious allegations. Employee(s) making such allegations will face disciplinary action, as appropriate.
Likewise, if investigations reveal that the external party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.
The Group encourages the whistle-blower to identify himself/herself when raising a concern or providing information. The whistle-blower's identity as well as concerns raised will be treated with strictest confidentiality.
Exceptional circumstances which information provided by the whistle-blower could or would not be treated with strictest confidentiality includes:-
In the event the Group is faced with a circumstance not covered by the above, and where the whistle-blower's identity is to be revealed, the Group will endeavour to discuss this with the whistle-blower first.
The Group will consider anonymous reports, but concerns expressed or information provided anonymously will be investigated on the basis of their merits.
Employees of the Group or external parties can address his/her concerns to the Independent Directors (which also the Whistle Blowing Committee), via email at whistleblowing@cytomed.sg. This email will be available in the Group's website for easy reference by the employee and external parties respectively.
Concerns or information are preferably raised or provided in writing to the abovementioned email. The aim of such arrangement is to ensure independent investigations of such matters and for appropriate follow-up actions.
The written report should at least consider the following information:
The earlier the concern is raised the easier it is for the Group to take effective action.
The Group expects the whistle-blower to provide his/her concern in good faith and to show to the appropriate officer that there are sufficient grounds for his/her concerns.
The Group assures that any legitimate concern raised or information provided will be reviewed and investigated if deemed necessary. The following factors will be taken into consideration:
Depending on the nature of the concern raised or information provided, the investigation will be conducted involving one or more of these persons or entities:
The amount of contact between the whistle-blower and the person(s) investigating the concern raised and information provided will be determined by the nature and clarity of the matter reported. Further information provided may be sought from the whistle-blower during the course of the investigation. When the investigation is completed, the investigating officer(s) will communicate the findings to the Audit Committee for its necessary action.