Frencken Group Limited is committed to high standards of corporate governance that encompass the ethical, moral and legal conduct of its business. An important aspect towards ensuring the adherence of this conduct is to provide an accountability and transparency mechanism that will enable individuals to voice concerns of perceived wrongdoings in a responsible and effective manner.

As part of its corporate governance framework, the Group has adopted a whistle blowing policy that ensures there is an avenue for employees to raise concerns in confidence and provide assurance that the party involved in the whistle blowing will be protected from reprisals, victimisation, harassment or disciplinary proceedings.

Frencken Group’s whistleblowing policy reinforces the value that it places on staff to be honest and upright in their dealings and conduct. It should be emphasised that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the Group nor should it be used to air grievances or as a platform to maliciously attack a superior for personal gain.

The Group’s whistle blowing policy applies to all employees of the group as well as suppliers, customers, outsourced partners, agents and consultants that have dealings with the Group.

Whistle Blowing Policy Framework

1. Expectations of appropriate conduct to be made known to all employees
   Employees are forewarned upfront that the Group expects honesty, integrity and high moral and ethics from all its employees. Expectations of appropriate conduct are communicated as follows:
   • All executives have to make a “Declaration of Conduct” upon confirmation of employment.
   • A code of misconduct is also spelled out in the employee handbook that is issued to each and every employee.

    

2. Ensure independence and impartiality of review
   The channel of communicating the whistle blowing event is separated from the management of Frencken Group to ensure there are independent and internal checks.
3. Mode of communication disseminated to all employees
   All whistle blowing communications will be directed confidentially to the Chairman of the Audit Committee who shall be an independent director of the board and not involved in the management of the Group.

Reporting and Communication Channel

Frencken Group has established a whistle blowing channel of communication for all its employees, as well as suppliers, customers, outsourced partners, agents and consultants that have dealings with the Group.

Appropriate matters of concern relating to the affairs of the Group can be raised by e-mailing directly to the Chairman of the Audit Committee at the following e-mail address: audit.chair@frenckengroup.com

All concerns raised will be independently assessed by the Chairman of the Audit Committee. Any individual making a whistleblowing report will retain his/her anonymity unless he/she agrees otherwise.