The purpose of the Policy is to:

• Provide a trusted avenue for employees, customers, vendors and other stakeholders to report serious wrongdoing or concerns, particularly in relation to fraud, controls or ethics, without fear of reprisals when whistleblowing in good faith; and
• Ensure that robust arrangements are in place to facilitate independent investigation of the reported concern and for the appropriate follow up actions to be taken.
• Promote a culture of openness, accountability and integrity.

This Policy applies to:

1. All employees in the Group
2. External parties (where relevant)
3. Third party representatives
4. Other stakeholders

It is to provide guidelines to the stakeholders for blowing the whistle about serious concerns about malpractices or suspected malpractices in the work environment for the EnGro Group.

Concerns about malpractices or suspected malpractices are considered as serious and should be disclosed in the reasonable belief that making a disclosure is beneficial to the EnGro Group if the concerns are about the following:

• a criminal offence, unlawful acts, fraud, corruption, bribery or blackmail has been committed, is being committed or is likely to be committed;
• a person has failed, is failing or is likely to fail to comply with any legal obligation to which he/ she is subject to;
• harassment and abuse and misrepresentation of power and authority;
• any concerns regarding questionable accounting, internal accounting controls or auditing matters;
• a miscarriage of justice has occurred, is occurring or is likely to occur;
• the health or safety of any employee has been, is being or is likely to be in danger;
• all forms of discrimination on the basis of gender, race, religion or disabilities.

• Employees

All employees have a responsibility to raise any concerns about malpractices or suspected malpractices in the EnGro Group either to his/ her superior or the WIO.

• Whistleblower Investigation Officer (“WIO”)

The Head of Internal Auditor is designated as the WIO who addresses the concern raised and carries out any investigation pertaining to the concern raised where appropriate. WIO will make a written record of any concern raised by a Whistleblower and provide feedback to the Whistleblower. WIO will also report the results of the investigation to the relevant authority (CEO or Chairman of Audit Committee if the concern involves the CEO).

• Whistleblower Protection Officer (“WPO”)

The CEO is designated as the WPO who protects the Whistleblower who raises genuine concerns from any form of victimization.

An employee (hereinafter referred to as the “Whistleblower”) may raise his/ her concern with his/ her immediate superior. Where the concern involves the immediate superior, the matter may be escalated to the next higher level of management. The superior shall follow up on the concern raised and provide feedback to the Whistleblower on the action to be taken.

Alternatively, the Whistleblower may report the concern directly to the WIO, i.e. the Head of Internal Auditor. External parties who wish to report concerns relating to misconduct, irregularities or malpractices within the EnGro Group may likewise raise such concerns with the WIO.

Concerns may be raised verbally or in writing. To enable EnGro Group to effectively assess and investigate a complaint, the report should be as detailed and specific as possible. The Whistleblower may complete the Whistleblowing Disclosure Form (refer to Appendix A), or use it as a guide for the required information, and submit it to the WIO. Submissions may be made to the WIO by mail and/or email as follows:

For concerns raised in writing, the following information should be provided:

• the background and history of the concern, including relevant dates and any supporting evidence to substantiate the issues raised; and
• the identities of the parties against whom allegations of malpractices or suspected malpractices are made.

The WIO shall independently assess all concerns raised to ensure that they are fairly and properly considered. Depending on the seriousness of the concern, the WIO may escalate the matter to the CEO. Where the concern involves the CEO, the WIO shall notify the Chairman of the Audit Committee.

Where the identity of the Whistleblower is known and the concern is raised in writing, the WIO shall acknowledge receipt of the concern. Such acknowledgment shall include an estimated timeframe for issuing a response and an indication of whether further investigation will be conducted and, if not, the reasons thereof.

Subject to the complexity of the matter, the Whistleblower shall be informed of the action to be taken within two to four weeks from the date the concern is raised. The WIO shall also report the results of the investigation to the relevant authority (the CEO or the Chairman of Audit Committee), as applicable.

All concerns raised by the Whistleblower shall be treated in confidence, and the identity of the Whistleblower shall be kept in the strictest confidence. Notwithstanding the foregoing, there may be circumstances in which the Whistleblower may be required to act as a witness in connection with the investigation.

This Policy encourages stakeholders, wherever possible, to disclose their identities when raising concerns, in order to enable the WIO to seek clarification on the information provided and to facilitate effective investigation and response. The WIO shall exercise discretion in determining whether concerns raised anonymously warrant immediate attention and further investigation.

In exercising such discretion, the following factors shall be considered:

• the seriousness of the issues raised;
• the credibility of the concern; and
• the likelihood of substantiating the allegation from attributable sources.