WHISTLEBLOWING POLICY
Version: June 2025
1. Purpose
The Durapower Group of Companies has set out in its Corporate Code of Conduct (the “CoC”) to present its commitment to achieve high standards of corporate governance towards all groups of stakeholders. This Whistleblowing Policy (WBP) provides employees with a reporting mechanism to report any wrongdoing in a responsible and effective manner, balancing protection of whistle blowers who report actual and material infringements of the CoC, while also protecting them against unfounded submissions or complaints.
Ultimately, the WBP shall assist the company, as a legitimate interest, to ensure that employees’ behaviors are aligned with the company’s Code of Conduct.
2. Scope
This WBP is intended to cover Durapower Holding Pte Ltd and all its subsidiaries. The WBP shall cover entities incorporated in Singapore and shall be adapted to entities incorporated in other countries for the WBP applicable to be aligned with local laws and regulations.
For the avoidance of doubt, this WBP is used by employee or any person to report perceived or actual instances of:
a. Corruption, fraud, embezzlement, theft,
b. Dishonesty
c. for personal benefit and/or benefit to others,
d. Danger (endangerment of) to personal/employee health and safety,
e. Damage or harm to the environment,
f. Intentional acts causing harm or loss to the Company,
g. Breaches of the Code of Conduct, and/or
h. Acts that are illegal or criminal, including acts against the law, government rules and regulations, including concealing or assisting in concealing once they have occurred.
3. Who Can Receive Whistleblow Complaints
Such employees or persons, including external parties, who have reasonable grounds to report perceived or actual instances of the above-mentioned matters, can report such misconduct via channels provided by Durapower, either with contact information, or, anonymously.
To ensure that all complaints are treated fairly and consistently, all complaints under the WBP are to be received at the email whistleblow@durapowergroup.com
4. Roles And Responsibilities Of The Whistleblowing Committees
a. Complaints Assessment Committee is granted the ability to:
i. decide whether a complaint or a series of complaints should result in a case to be sent to the Senior Management Whistleblowing Committee,
ii. decide whether a complaint or series of complaints is an abuse of the WBP and determine follow-up action if there is abuse of the WBP.
For the avoidance of doubt, the Complaints Assessment Committee exercises sole and absolute discretion on whether to proceed with 4(a)(i) and/or 4(a)(ii). This exercise of discretion shall be absolute and the Complaints Assessment Committee need not respond to any claims about the substance and/or basis of its findings or actions.
b. Senior Management Whistleblowing Committee is granted the ability to:
i. decide whether a complaint or a series of complaints is an infringement of section 2 above, based on submitted evidence or material,
ii. decide whether to procure additional information or data to determine whether an infringement of section 2 is made out,
iii. terminate an investigation or to procure additional information or data,
iv. decide whether to form an investigation group to further investigations required to substantiate the complaint.
v. deliver a final investigation report setting out recommended actions and any relevant policy changes.
vi. decide any recommended follow-up actions are to be taken, and,
vii. decide if any complaint or complaints determined by the Complaints Assessment Committee to be an abuse or misuse of the WBP shall lead to further actions against the person abusing or mis-using the WBP.
For the avoidance of doubt, the Senior Management Whistleblowing Committee is granted the ability to undertake such investigations required, and, close and/or terminate investigations and/or the complaint. For the avoidance of doubt, the Senior Management Whistleblowing Committee exercises sole and absolute discretion in its actions in this section 4(b). This exercise of discretion shall be absolute and the Senior Management Whistleblowing Committee need not respond to any claims about the substance and/or basis of its findings or actions.
4.3 Senior Management Whistleblowing Committee is granted the ability to:
a) decide which of the recommended follow-up actions are to be taken,
b) decide whether policy changes or further communication of policy are required, and
c) decide if any complaint or complaints determined by the Complaints Assessment Committee to be an abuse or misuse of the WBP shall lead to further actions against the person abusing or mis-using the WBP.
For the avoidance of doubt, the Senior Management Whistleblowing Committee is granted the ability to close and/or terminate investigations and/or the complaint.
5. Whistleblowing Process And Assessment
5.1 The Complaints Assessment Committee shall receive and assess complaints and information in a timely manner while still reserving the rights of employees or whistle blowers to anonymity when submitting a case and reserving the rights of employees or whistle blowers against misuse or abuse of the WBP.
5.2 As indicated in paragraph 3 above, complaints and information shall be received at email whistleblow@durapowergroup.com only by the Complaints Assessment Committee. The Complaints Assessment Committee shall presently be formed by Durapower Group CEO and Durapower Head of Group HR.
5.3 The Senior Management Whistleblowing Committee shall be made up of the Complaints Assessment Committee and the Heads of Department of Durapower.
5.4 At any time or instance when one or more persons of either the Complaints Assessment Committee or the Senior Management Whistleblowing Committee shall be the subject of a WBP complaint, such persons shall immediately remove themselves from the WBP complaint process and shall be excluded entirely from any meetings, investigations, or actions. When any one person or persons are excluded from the committees for any one complaint, such persons shall not be involved in any other complaints or cases.
5.5 Complaint Assessment Criteria. Both the Complaints Assessment Committee or the Senior Management Whistleblowing Committee shall take note of the following guidance on the assessment of WBP complaints. A valid complaint shall contain actionable and comprehensible information, even if the information is incomplete. A valid complaint shall contain at minimum,
a. Name(s) of person(s)/company(ies) involved in infringement of section 2 above,
b. Detailed description of the incident (including date, time, location, methods and action/ behaviour) evidence, and
c. Any other information that may substantiate the incident. (I.e. documents, pictures, audio or video recordings, additional witnesses accounts, etc.).
For the avoidance of doubt, an anonymous submission of information or complaint shall be permitted under the WBP. However, if the submission is totally anonymous, not less than three (3) pieces of the above-mentioned information in 4.3 (a), (b) and (c) shall be submitted for the complaint to be considered to be a valid complaint. The Complaint Assessment Committee reserves all rights and the sole discretion to disregard anonymous submissions if the Committee determines that inadequate information has been received. The Complaint Assessment Committee may be more open to non-anonymous information or complaint submissions since vague or unclear elements of a complaint can be clarified with a known complainant. However, depending on the severity of the complaint and any exigencies resulting in actions having to be taken expeditiously, the Complaint Assessment Committee reserves the right to exercise its discretion to escalate a case or complaint immediately even if the criteria stated above are not met.
5.6 Where it is clear to either committee that a case or complaint has been filed either negligently or recklessly or purposefully to, without any reasonable basis, cause any inconvenience, harm or loss to any person, who may or may not be a subject of a case or complaint, either committee shall make a decision to not proceed with the case or information provided, and, shall determine and recommend follow-up actions on such abuse or mis-use of the WBP.
5.7 Where it is clear to either committee that a case or complaint has been filed either negligently or recklessly or purposefully to, without any reasonable basis, cause any inconvenience, harm or loss to any person, who may or may not be a subject of a case or complaint, either committee shall make a decision to not proceed with the case or information provided, and, shall determine and recommend follow-up actions on such abuse or mis-use of the WBP.
5.8 Any receipt of personal information, including names, identifying features, telephone numbers, photographs, images, shall be kept private and confidential, but at the same time, this WBP operates in compliance with local laws and regulations regarding the protection of personal information since such receipt of personal information clearly falls under the “legitimate interest” exception to the PDPA of Singapore as it is a legitimate interest of the pertinent Durapower group of companies to have a WBP in operation.
6. Whistle Blow Policy Process Flow
6.1 The following is a brief description of a valid case or complaint under the WBP:
a) A case or complaint is submitted through the designated channels.
b) The case or complaint shall be assessed by the Complaints Assessment Committee.
c) A valid complaint shall be submitted by the Complaints Assessment Committee to Senior Management Whistleblowing Committee.
d) The Senior Management Whistleblowing Committee shall undertake investigations.
e) When the investigations are complete or at a stage material to the case, Senior Management Whistleblowing Committee shall produce a case report and then decide whether and how to undertake the recommendations therein or decide any other actions to be taken. e.
f) When all action items and recommendations arising from a case report have been done and completed, the Senior Management Whistleblowing Committee shall table a meeting resolution to consider and decide whether a WBP case has been closed.
6.2 Other process flows dealing with anonymous case or complaint submissions, and the process to deal with misuse or abuse of the WBP are as described in Section 4 above.
7. Communication
7.1 For internal communications, Durapower will communicate and disclose this Whistleblowing Policy and whistleblowing channels through employee orientation, training, publishing in workplace and via Company’s electronics system, etc. to assure the understanding of the employees and their strict compliance under this policy.
7.2 For external communications, Durapower will communicate and disclose this Whistleblowing Policy and whistleblowing channels to public, subsidiaries, affiliates and stakeholders through several channels such as website, annual report, Sustainability Report, etc.
8. Review and Revision
8.1 This Policy will be subject to periodic review by Durapower in general to ensure its relevance and effectiveness.
8.2 Any necessary revisions will be communicated to all relevant stakeholders.
