This Whistle-blowing Policy is intended to provide a framework to encourage the REIT Manager's employees and stakeholders such as customers, suppliers and service providers to use the procedures set out in the policy to report any concern or complaint, possible improprieties in matters of financial reporting, and other malpractices.
The REIT Manager strictly prohibits frivolous and untrue complaints.
An annual review of the Whistle-blowing Policy will be conducted by the management and the Audit and Risk Committee (ARC) to ensure that related changes in legal and regulatory requirements are updated and the arrangements have been effective.
Scope of Improprieties
The REIT Manager does not tolerate any wrongful act or impropriety (including without limitation fraud, theft, dishonest acts, profiteering, corruption, bribery, intimidation, discrimination, harassment, criminal offences, failure to comply) by its employees.
The scope of the whistle-blowing report may include the following:
Unethical and improper practices or alleged wrongful conduct relating to financial reporting or other related matters;
Non-compliances with regulatory requirements or corporate policies relating to financial reporting or related matters;
Questionable or suspicious practices relating to accounting policies/ treatment or audit matters; and
Any other acts that may have a material impact on the REIT Manager's operating results or financial position.
Whistle-blowing Reporting Channels
Any wrongdoing or concerns should be referred to the Chairman of the ARC at arcchair@sasseurreit.com.
The whistle-blowing reports should include the following information, where applicable:
Date, time and place of the actions/transactions;
Identity and particulars of parties involved;
Circumstances leading to the improprieties; and
Any other relevant information or documentation that would assist in the evaluation of the report.
Upon receiving a whistle-blowing report, an email will be sent to the whistle-blower to acknowledge receipt of the report within 3 working days.
Whistle-blowers will be informed of who is handling the matter, how they can make contact with them and if there is any further assistance required.
Confidentiality of Whistle-blowing Reports
Whistle-blowing reports will be handled confidentially, to the extent permitted by laws and regulations.
The whistle-blowing reports and related documents will be password protected and shared only with appropriate persons. Furthermore, hard copies of documents in relation to whistle-blowing reports will be kept under lock and key.
Employees' and any other persons' identities will not be disclosed without prior consent.
Where concerns are unable to be resolved without revealing the identity of the whistle-blower, the matter will be discussed with the whistle-blower as to whether and how the REIT Manager can proceed.
The REIT Manager reserves the right to refer any concerns or complaints to appropriate external regulatory authorities.
Depending on the nature of the report, the subject of the report may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations.
Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.
Investigations of Whistle-blowing Reports
All concerns raised will be treated fairly and properly.
Following a review of the complaint or concern, the Chairman of the ARC, where appropriate, will take steps to have the matter investigated. The Chairman of the ARC may appoint one or more of the following independent parties to conduct investigations in relation to the whistle-blowing report:
External parties such as Company Secretary, legal adviser, outsourced IA firm;
Head of IA department; or
Dedicated team or department that handles investigations of misconduct or any other matters and has a direct reporting line to Independent Directors.
The timeframe for the investigation and resolution of matters will be determined on a case-by-case basis by the Chairman of the ARC and the appointed parties.
Concerns expressed anonymously will be 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.
If, at the conclusion of an investigation, it is determined that a violation has occurred or the allegations are substantiated, remedial action commensurate with the severity of the offence will be taken.
All subsequent actions and decisions taken following the receipt of whistle-blowing reports will be documented and circulated to the ARC or tabled for discussion every quarter.
Protection against Reprisals
The REIT Manager will not tolerate the harassment or victimisation of anyone raising a genuine concern;
The REIT Manager will ensure that no one will be at risk of suffering from retribution as a result of raising a concern even if they are mistaken, unless the individual raises a matter they know to be untrue.
