Elite Commercial REIT Management Pte. Ltd. (“ECRM” or “the Company”), part of the Elite Partners Group, is organised under the laws of Singapore and its operations are subject to the laws of Singapore. ECRM is committed to achieving its business objectives through ethical and excellent conduct. Integrity is one of ECRM’s core values and the Company is committed to high standards of corporate governance and accountability in its affairs.
“Whistleblowing” refers to the making of certain disclosures (via a dedicated and clearly communicated reporting mechanism) of actual, suspected, or potential (or “reasonably anticipated”) conduct that an individual reasonably believes to be unlawful. Therefore, disclosures can be made by any third party engaged in a business relationship with ECRM about serious breaches observed in their dealings with ECRM. This includes the reporting of information alleging serious breach of laws, regulations, or ethics by another ECRM employee(s). You are encouraged to raise genuine concerns about possible improprieties in the conduct of ECRM’s business, whether in matters of financial reporting or other malpractices, at the earliest opportunity in an appropriate way.
MAKING A WHISTLEBLOWING REPORT
A compliance concern is only protected under the ECRM’s Whistleblowing Policy where it is a Qualifying Disclosure made in good faith and where you reasonably believe at the time that a serious breach has been, is being, or is likely to be committed. A Qualifying Disclosure is defined as “any good faith communication based on reasonable grounds that discloses or demonstrates an intention to disclose information that may evidence a serious breach”. Compliance concerns may be raised verbally or in writing.
It is necessary that all vital information is provided in order to facilitate the investigation of any concerns effectively. As such the Whistleblowing Report should be as specific and detailed as possible. It should contain at least the following information:
- Parties involved (Who);
- Type of Serious Breach involved (What);
- Dates or period of time (When);
- Location where the Serious Breach was conducted (Where);
- Apparent motives (Why);
- Methods used to conduct the Serious Breach (How); and
- Evidence substantiating the Compliance Concern.
Incidents of actual or suspected Serious Breaches should be promptly reported to firstname.lastname@example.org, or the postal address 9 Temasek Boulevard, #17-01, Suntec Tower 2, Singapore 038989 (with attention to the Audit and Risk Committee Chairman).