TSAO Foundation is committed to a high standard of compliance with corporate governance standards, accounting and financial reporting standards, internal controls and auditing requirements and any legislation relating thereto. In line with this commitment, this policy aims to provide an avenue for employees and external parties to raise concerns and offer them reassurance that they will be protected from reprisals or victimisation for whistle blowing in good faith.

Scope
This policy applies to all employees as well as to all external parties who have business or other relationships with TSAO Foundation. These parties include customers, suppliers, contractors, applicants for employment, and the general public.

Definition
Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organisational malpractice by a person who has or has had privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing within or by TSAO Foundation that is within its ability to control.

Reportable Incidents
Below is a list of examples (though not exhaustive) of reportable incidents covered by this policy concerning Tsao Foundation’s corporate governance, accounting and financial reporting, internal controls, or auditing matters:

• Impropriety, corruption, acts of fraud, theft and/misuse of Tsao Foundation’s properties, assets, or resources;
• Conduct which is an offence or breach of law;
• Serious conflict of interest without disclosure;
• Breach of Tsao Foundation’s policies or code of conduct;
• Unsafe work practices, health and safety risks, harassment, discrimination, victimisation or bullying;
• Manifestation of intention to mislead, deceive, coerce, or fraudulently influence;
• Concealing information about any of the above malpractices or misconduct;
• Any other serious improper conduct that may cause financial or non-financial loss to Tsao Foundation or damage its reputation.

Protection against Reprisal and Confidentiality
When raising concern or providing information about an actual, suspected, or anticipated wrongdoing, done in good faith, the individual, be it an employee or anyone else, shall be protected against any reprisal such as employment termination, retribution, or harassment. Tsao Foundation will not tolerate any retaliation against any person that has raised concern or provided information about any actual, suspected or anticipated wrongdoing. Further, all care will be taken to restrict the disclosure of the identity of such person, which shall be treated as confidential information at all times.

It is recognised that an individual may choose to remain anonymous in certain cases. Concerns or information provided anonymously will still be given due consideration by Tsao Foundation but will be investigated on their own merits.

False or Unethical Reports
This policy is initiated by Tsao Foundation in good faith and with the aim of inculcating a culture of good governance and high ethical behaviour. As such, it is assumed that all reports are made with similar purpose and with no malicious intent to hurt or cause grievance to others. Tsao Foundation will not tolerate false and irresponsible reporting, and where it is established that an employee has knowingly made a false report, this will be regarded as a serious disciplinary matter and dealt with in accordance with the applicable disciplinary procedures.

Reporting Procedure
Concerns may be raised with or information provided to the following:

Such reports are preferably made in writing, in the form of a letter, and in detail setting out the background and history of events as well as the reason(s) for concern.

Alternatively, reports with supporting documents detailing the background, history of events and reasons(s) for concern, may be emailed to whistleblowing@tsaofoundation.org.

In the event that any reports are sent to, and received by, HR Department or Tsao Foundation management, the recipient shall forward such report to the Audit Committee Chairman and notify the sender of the same.

Investigation Process
Tsao Foundation takes every report submitted seriously. Upon receiving a report, the Audit Committee Chairman will immediately look into it and determine as soon as possible whether or not an investigation of the issue raised in the report should be carried, after assessing the materiality or relevance of the concern or information provided.

Assessment of the concern or information shall be made with due consideration given to the following factors:

• Seriousness of the issue raised;
• Credibility of the concern or information; and
• Likelihood of confirming the concern or information from the attributable sources.

If the issue raised in the report warrants investigation, the Audit Committee Chairman will determine the appropriate stakeholders that will act as the investigating officer(s) within 7 days of the assessment referred to above. The investigating officer(s) shall commence work immediately upon appointment and shall report directly to the Audit Committee on the progress of the investigation.

The amount of contact between the whistle blower (if not anonymous) and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistle blower during the course of the investigation.

The Audit Committee is authorised and empowered to take all steps to facilitate the conduct and completion of the investigation by the investigation as soon as practicable. When the investigation is completed, the investigating officer(s) will submit a report to the Audit Committee detailing the following for its necessary action:

• Full findings of the case;
• Corrective actions recommended, if any;
• Recommended changes to existing processes / procedures to ensure that violations will not be repeated, if any.