1. Purpose & Scope

The Group does not tolerate any malpractice, impropriety, statutory non-compliance, or wrongdoing by any employee in the course of their work. This Whistleblowing Policy (the “Policy”)is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences.

Employees and outside parties, such as suppliers, customers, contractors, and other stakeholders, may use the procedures set out in the Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, insider trading, collusion with competitors, serious breaches of Group policy, unsafe work practices or any other matters involving fraud, corruption, and employee misconduct.

The Policy allows for reporting by employees or outside parties of such matters to the Human Resource Division of the Group, without fear of reprisal, discrimination or adverse consequences, and also permits the Group to address such reports by taking appropriate action, including,
but not limited to, disciplining or terminating the employment and/or services of those responsible.

The Policy is meant to protect genuine whistleblowers from any unfair treatment as a result of their report. Frivolous and bogus complaints will be disregarded. The Policy is also not a route for taking up personal grievances or providing feedback on the services provided.

2. Policy Statements

• What the Group requires you to report:

Subject to local laws and regulations, the Group requires you to promptly report any actual or potential wrongdoing at or in relation to work. (See Section 3)

• Reporting Concerns:

You should feel able to raise concerns internally through designated internal reporting contacts. (See Section 4)

• What will happen if you raise a concern:

Concerns that are raised will be assessed initially to determine whether an investigation is necessary and, if so, the scope of any investigation. Investigations will be undertaken in a timely manner. (See Section 5)

• Receiving Concerns:

When a concern is raised to you, it should be dealt with expeditiously using the most appropriate reporting mechanism(s). (See Section 6)

3. What you should report

The Group encourages employees and outside parties to put their names to their allegations whenever possible. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided.

You should make the disclosure in good faith and in the reasonable belief that a wrongdoing has been, is being or likely to be committed. Any actual or potential breach of any law or regulation related to the Group’s business would constitute wrongdoing for these purposes, as would, subject to local laws, a breach of the Group’s policies and procedures (including this Policy).

You may raise concerns regarding your own personal circumstances, such as concerns or grievances regarding working relationships, through the mechanisms set out in section4.

4. Internal contacts for raising concerns

When reporting internally, you should consider, in the first instance, raising concerns with your immediate supervisor. However, if you feel unable to do so, please contact the Receiving Officer. The Receiving Officer is Mr. Lim Tai Toon, Lead Independent Non-Executive Director. The contact email is compliance@medinex.com.sg.

Concerns may be raised verbally or in writing. As it is essential for the Group to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The complaint should include details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible, and contact details, in case further information is required.

5. What will happen if you raise a concern

All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.

All matters reported will be reviewed within a reasonable timeframe, and after due consideration and inquiry, a decision will be taken on whether to proceed with a detailed investigation. Guidance/direction may be sought from the CEO and other appropriate parties.

Where the complaints relate to a senior executive and/or the CEO, the Receiving Officer will escalate these to the Board.

Sometimes the need for confidentiality may prevent the Receiving Officer from discussing with you the specific detail of an investigation, any outcomes, or actions taken. You should also treat any information about the investigation as confidential.

The Group strictly prohibits intimidation, victimization, or retaliation against any employees who report concerns in relation to any actual or potential wrongdoing as well as anyone who assists with any inquiry or investigation arising from a reported concern. This is the case even if, as a result of an investigation based upon your report, we determine that there was in fact, no wrongdoing. However, if you made a false and malicious disclosure or intentionally provided false information, the Group may take disciplinary action against you.

Additionally, if you participated in the wrongdoing, the Group may take disciplinary action against you in relation to the wrongdoing.

6. Receiving Concerns

When a concern is raised to you, it should be dealt with expeditiously and treated with confidentiality. You can refer a concern raised to you using the most appropriate reporting mechanism set out in Section 4.

7. Modification

The Group may modify this Policy to maintain compliance with applicable laws and regulations or accommodate organizational changes within the Group.

8. If you have questions about this Policy

If you are unsure as to the appropriate course of action, you are encouraged to seek guidance from your manager/supervisor or the Head of Human Resources.

Defined Terms

Board: Board of Directors of Medinex Limited
Group: Medinex Limited and its subsidiaries
Receiving Officer: An officer who has been designated to manage concerns in the Group

Updated July 2023