1. Introduction
Golden Equator Capital Pte. Ltd. (the “Company”) is regulated by the Monetary Authority of Singapore, Singapore’s central bank and integrated financial regulator. The Company and its board of directors (the “Board of Directors”) are fully committed to conducting business with integrity and the highest ethical standards while complying with the applicable laws and regulations.
In line with this commitment, this Whistleblowing Policy (this “Policy”) is established to ensure the necessary communication channels are available. This Policy is also aligned with the Company’s aim to cultivate a culture of accountability, integrity and support within the community.
The Policy is to be read in conjunction with the Securities and Futures Act 2001 of Singapore, as may be amended from time to time.
2. Objective and Scope
Anyone has the right to whistleblow. This Policy is applicable to all employees, directors, officers, agents, representatives, vendors, associated stakeholders and clients of the Company.
The objective of this Policy is to:
- Provide a trusted avenue for all parties mentioned above to report serious wrongdoing or raise concerns in relation to possible fraud, improper and unethical conduct without fear of reprisals when whistleblowing in good faith.
3. Key Principles
This Policy of the Company is structured around 3 key principles: (i) the protection of confidentiality, (ii) the prevention of victimization and the non-retaliation principle, and (iii) the protection of the accused person.
(i) Protection of confidentiality
Confidentially is the cornerstone of this Policy. The recipient of the whistleblowing report and all others involved in the whistleblowing process will treat the information with the intention that such information may only be disclosed on a “need-to-know” basis. The identity of the whistleblower will not be revealed without first obtaining the whistleblower’s explicit consent, unless its disclosure is required in response to a valid court order or by the law. The whistleblower will be given prior notice before any such disclosure.
On the basis that the whistleblower’s identity is intended to be kept anonymous, the Company encourages each whistleblower to disclose his/her identity or provide contact details when reporting a concern in order to facilitate any follow-up actions. Anonymous reporting is, nevertheless, a possibility should this be required and a whistleblowing report will not be disregarded solely on the basis that it had been made anonymously.
(ii) Prevention of victimization and the non-retaliation principle
The protection of whistleblowers is of paramount importance to the Company. The Company will ensure to the best of its ability that employees who have filed a report or raised their concerns via any of the whistleblowing communication channels in good faith will be appropriately protected from any negative impact such as harassment, retaliation, discrimination or other types of unfair treatment. Retaliation includes any adverse action taken inappropriately against the whistleblower such as demotion, firing, salary reduction, etc.
Appropriate measures will be taken against any employee who engages in retaliatory actions towards a whistleblower. Such measures can take the form of disciplinary actions, including the possibility of dismissal.
A report is made in good faith if the relevant individual has reasonable grounds to believe the information was true at the time of reporting. If you believe you have suffered adverse consequences as a result of making a whistleblowing report, please inform the receiving officers in accordance with the information in section 4.1, who will arrange for an independent investigation into the matter.
(iii) Protection of the accused person
Similarly, for the person being accused of alleged impropriety, his/her employment rights and right to privacy will need to be carefully considered. The person who is the subject of an investigation may be informed about the cause if appropriate.
If the investigation finds no evidence that justifies the allegations on the accused person, the accused person should be protected from any negative impact. Even if the outcome of the investigation validates the whistleblower’s concern and corrective measures are taken, the accused person should be protected from unintended or disproportionate negative effects that go beyond the objective of the corrective measures.
4. Reporting Procedures
Whistleblowing reports on any improprieties made in good faith should be in writing with the following information:
- Details of the party(ies) involved (including the accused person, any victim and all other relevant persons, whether such person is from or affiliated to the Company or not, collectively the “Concerned Parties“)
- Date/period of incident (please indicate if this is an ongoing issue)
- Type of concern
- Evidence substantiating the report (where it is not possible, please provide a paragraph with as much details as possible supporting the report)
- Contact details (while this has been requested for in case further information is required, however, in the event that a whistleblower is adamant in lodging it as an anonymous report, these may be omitted)
4.1 Communication Channels
Reports can be made via any of the communication channels below. The receiving officers of the report are: The Chief Operating Officer and/or Head of People Experience Management.
Email: [email protected]
OR
You may mail your report to the following address:
Golden Equator Capital Pte. Ltd.
Attn: (Chief Operating Officer / Head of People Experience Management)
3 Fraser Street #05-28 DUO Tower Singapore 189352
4.2 Handling of Whistleblowing Reports
All concerns raised will be presented to the Board of Directors and the Board of Directors will decide on who will lead the investigation. In the event that any Director is a Concerned Party, he/she should be excluded when such report is being presented and should not receive any notice of the existence of such a report or investigation. Unless there is a particular reason to the contrary, the receiving officer shall ensure that the whistleblower’s identity is not revealed to the Board of Directors. To the extent practicable, at this point, the Concerned Parties’ identities should also be kept anonymous (including that of the accused persons).
The lead of the investigation may at his/her discretion form a team comprising of a group of employees perceived by the Board of Directors to be independent for the purpose of conducting a detailed investigation of the report. At no point of time shall any person on team be a Concerned Party.
The outcome of the investigation will be presented to the Board of Directors, who will then make a collective decision on corrective measures to take, if applicable. The whole process shall be documented in a written report and kept by the Receiving Officers for a minimum period of 5 years.
In the case where the whistleblower reveals their identity or leaves their contact information, the Company will acknowledge receipt of their report in writing within a reasonable period after the report is received, and in any event within 2 weeks. Where deemed appropriate by the Company under the circumstances and provided that such whistleblower has indicated his/her contact details in the report, the Company will keep the whistleblower informed of the progress of the investigation.
5. Alternative External Reporting Channel
The Company encourages direct reporting of any suspected improprieties to the Company through its whistleblowing channels as the Company is responsible for investigations into the reported improprieties.
In the event that the whistleblower is not satisfied of the outcome of the Company’s investigation and would like to make a report to an external party, the individual may do so via the Online Feedback Form on the MAS’ website:
Receiving Party: Monetary Authority of Singapore
Online Feedback form: https://eservices.mas.gov.sg/consumerfeedback/
Last Updated 27 April 2023
