Version Number: WP-1
PSC CORPORATION LTD.
WHISTLEBLOWING POLICY
1. INTRODUCTION, PURPOSE & SCOPE
1.1 This Whistleblowing Policy (“this Policy”) is established to encourage the reporting of suspected misconduct, unethical behaviour, or any violation of law or company policy within PSC Corporation Ltd. and its subsidiaries (“the Group“) in a responsible and secure manner. The objective is to foster a culture of openness, accountability and integrity.
1.2 This Policy allows employees and third parties to raise a potential concern about some form of wrongdoing which is happening, has happened or is likely to happen and is in the public interest. The wrongdoings might fall into one or more of the following categories, including but not limited to: –
(i) A criminal offence (e.g. fraud);
(ii) A failure to ensure reliable and truthful financial reporting;
(iii) A miscarriage of justice;
(iv) A danger to the health and safety of any individual;
(v) Sexual Harassment in workplace;
(vi) Damage to the environment;
(vii) Deliberate attempt to conceal or assist any of the above;
(viii) Action or speech that may have negative or significant impact to the Group’s reputation and/or performance;
(ix) Any concerns in relation to a breach of the Group’s Policies on:
(a) Anti-Bribery & Corruption Policy;
(b) Human Rights Policy; and/or
(c) Environmental Policy
(collectively referred to as “Alleged Wrongful Act”).
1.3 The Group is committed to the highest possible standards of corporate governance and this Policy aims to provide an avenue for the Whistleblower who may be an employee or external party (“Whistleblowers”) to come forward to report an Alleged Wrongful Act without fear or favour.
2. CONFIDENTIALITY
2.1 The Group aims to create and maintain an environment that any Whistleblower feels safe and able to voice whistleblowing concerns openly under this policy.
2.2 Every reasonable effort will be made to protect the Whistleblower’s identity. However, it is important to be aware that it may be necessary to reveal the identity of the Whistleblower to assist in an investigation where: –
(i) the law requires; or
(ii) information is already in the public domain; or
(iii) information is given on a strictly confidential basis to external advisers who have been engaged by the Group to assist in the investigation of the Alleged Wrongful Act; or
(iv) information is disclosed to the relevant authorities for investigation.
2.3 Based on the nature of the reported case and investigation requirement, there may be a need to contact Whistleblowers. As such, anonymous disclosure may not be viable as proper investigation may be more difficult or impossible if the Group is not able to obtain further information from Whistleblowers and it is also more difficult to establish whether such allegations are credible. Knowing the identity of a Whistleblower also facilitates feedback to the Whistleblower in respect of action taken. The identity of Whistleblowers will only be shared on a need-to-know basis solely for the purpose of investigation. Anonymous disclosure will still be investigated, but consideration will be given to the:
(i) severity of the issue(s);
(ii) credibility of the concern; and
(iii) likelihood of securing confirmation from attributable sources,
in relation to the Alleged Wrongful Act.
2.4 Whistleblowers who are concerned about possible reprisals if their identity is revealed are encouraged to come forward to the Chairman of the Audit and Risk Committee of the Group and appropriate measures can then be taken to preserve confidentiality.
2.5 Although the Whistleblower is not expected to have all the evidence to sufficiently prove his/her allegation against the party in question, the Whistleblower is, however encouraged to provide relevant evidence that he or she possesses or made available to him/her to demonstrate that there are justifiable grounds to warrant a whistleblowing, thereby for the Group to put in resources to carry out an investigation.
3. PROTECTION & SUPPORT FOR WHISTLEBLOWERS
3.1 The Group does not tolerate any retaliation against an employee who whistleblows in good faith. Examples of retaliation may include dismissal, demotion and personal attacks. Retaliation also includes subtle actions such as avoiding or ostracizing; leaving him or her out of professional or social activities and so on. Retaliation can be a ground for disciplinary action in such situations.
3.2 However, an employee who knowingly makes an allegation that is false, frivolous or malicious will be in violation of this Policy and will be subject to disciplinary action in accordance with the law and/or workplace policies of the Group.
3.3 Likewise, if investigations reveal that an external party making an allegation through the whistleblowing channel in bad faith or for personal gain, the Group reserves the right to refer the matter to the relevant authorities.
4. REPORTING CHANNELS
4.1 Whistleblowers may report concerns through the following secure and confidential channels:
(i) Whistleblowing Email: whistleblowing@psccorporation.com;
(ii) By hand or by registered post under a sealed envelope to be addressed to:
Chairman of the Audit and Risk Committee, PSC Corporation Limited
c/o Whistleblowing Investigation Officers
348 Jalan Boon Lay
Singapore 619529.
and marked with “Private and Confidential”.
4.2 All whistleblowing cases shall be reported to the Chairman of the Audit and Risk Committee who is assisted by two independent Whistleblowing Investigation Officers appointed by the Audit and Risk Committee.
4.3 All whistleblowing reports shall be acknowledged and investigated promptly with the strictest confidentiality.
5. INVESTIGATION AND FOLLOW-UP
5.1 In consultation with the Audit and Risk Committee, the Whistleblowing Investigation Officers will identify and evaluate evidence provided by a Whistleblower to determine whether it is necessary to broaden and deepen their understanding of the issues raised before deciding if they should contact the Whistleblower (if contacts are provided) and/or to proceed with an investigation.
5.2 If an investigation is deemed necessary, the Audit and Risk Committee may direct the investigation to be carried out in the following manner:
(i) Whistleblowing Investigation Officers to conduct the investigation by themselves if the Alleged Wrongful Act is considered to be straightforward; or
(ii) Internal Audit and Whistleblowing Investigation Officers to jointly conduct the investigation if the nature of the Alleged Wrongful Act demands more resources and manpower; or
(iii) engage a firm of external specialists with expertise and proven track record to investigate the Alleged Wrongful Act that is exceptionally challenging.
5.3 The findings submitted by the Whistleblowing Investigation Officers to the Audit and Risk Committee should be clear, concise and substantive; this includes setting out the background, chronology of events and reasons of the concern in order to provide critical information to the nature of the Alleged Wrongful Act. Although the Whistleblower is not expected to have all the evidence to sufficiently prove his/her allegation against the party in question, the Whistleblower is, however encouraged to provide relevant evidence that he or she possesses or made available to him/her to demonstrate that there are justifiable grounds to warrant a whistleblowing; thereby for the Group to put in resources to carry out an investigation. If the Whistleblower is uncomfortable to write in, the Whistleblower can request to meet the Whistleblowing Investigation Officers on a confidential basis at a time and location suitable to both parties by sending a request via email to the Whistleblowing Email stated herein.
5.4 A report on the findings of the investigation and recommendations in relation to the Alleged Wrongful Act will be submitted to the Audit and Risk Committee for consideration and thereafter to the Board for information. Investigation results are confidential and cannot be disclosed or discussed with anyone other than those with a legitimate need to know. If the Whistleblowers is contactable, the notification that action has been taken will be given to the Whistleblowers without disclosing the detailed findings of the Alleged Wrongful Act.
6. MALICIOUS OR FALSE ALLEGATIONS
6.1 While Whistleblowers are encouraged to report suspected misconduct, intentionally making false or malicious allegations is a serious offence and may lead to disciplinary or legal action.
7. RECORD KEEPING AND REPORTING
7.1 All whistleblowing reports, investigation notes, and outcomes shall be documented and retained securely for a period of seven (7) years from the date of receipt of the whistleblowing reports. The Audit and Risk Committee shall review each report and give direction as it deems fit and necessary. Notwithstanding any provision in this Policy, the Whistleblowing Investigation Officers shall immediately notify and update the Chairman of the Audit and Risk Committee about the progress of investigation and findings of the Alleged Wrongful Act that has been reported.
7.2 In the event that the Alleged Wrongful Act reported by the Whistleblowers entails any of the Whistleblowing Investigation Officers or a member of the Audit and Risk Committee, the person in question shall forthwith recuse himself or herself from the case. The Chairman of the Audit and Risk Committee will either appoint another person as a replacement Whistleblowing Investigation Officer or engage an independent specialist outside the Group to review the case.
8. COMMUNICATION
8.1 This Policy and any subsequent modification thereof shall be made known to all the directors, officers and employees and publicly disclosing to the public on the Group’s corporate website.
9. REVIEW OF POLICY
9.1 The Audit and Risk Committee is responsible for the maintenance, review and updating of this Policy. Any revisions shall be approved by the Board of Directors.
Effective Date: 1st April 2026
Approved By: Board of Directors