1.    Policy Purpose and Scope

1.1. Watson E.P. Industries Pte Ltd (“WEP”) aims to maintain the highest standards of openness, integrity and accountability to its work. In line with this commitment, this whistleblowing policy (the “Policy”) aims to provide an avenue for employees and/or external parties to disclose in confidence and without fear of reprisal, possible wrongful conduct committed within or by WEP, for appropriate investigation and

1. 2. Wrongful conduct includes but is not limited to the following:

1.2.1. Financial or non-financial malpractice, including fraud, corruption, bribery or theft, money laundering, supporting terrorism.
1. 2.2. Harassment, abuse and misrepresentation of power and authority;
1. 2.3. Non-compliance with laws and regulations;
1. 2.4. Any conduct that may be detrimental to the health and safety of an individual or the environment;
1. 2.5. Discrimination on the basis of age, gender, religion, race, sexual orientation or disabilities;
1. 2.6. Serious conflict of interest without disclosure;
1. 2. 7. Breach of WEP’s constitution, by laws, policies or internal controls, including the Data Protection Policy;
1. 2.8. Improper or unethical conduct (including actions or conduct that have a detrimental impact on the WEP, including the reputation of the WEP);
1. 2.9. Unlawful activities; and

1. .2.10. Concealing information about any of the above malpractice or

2. How to make a report

2. 1. Employees of WEP (including part-time staff and interns) and external parties (including partner organisations, vendors, suppliers, service providers, agents, contractors or sub-contractors) are encouraged to raise any concerns of possible misconduct by or within WEP, in good faith, without malice, and with reasonable grounds for suspecting that misconduct has occurred.

2. 2. Concerns should be raised promptly by email to whistleblow@watsonep.com.sg , which will be received by the WEP HR and Directors, collectively know as “Receiving Parties”. The Receiving Parties are responsible for the investigation, handling and escalation of reportable concerns. As much details should be included as possible in relation to the following: Name(s) of person(s)/company(ies); Concerns raised anonymously will not be considered.

2. 3. Depending on the severity of the incident, an investigation may be carried out. The whistle-blower must not carry out his or her own investigations as this could result in the destruction or contamination of evidence or put his or her own safety at

2. 4. Following the investigation, subject to any legal constraints and confidentiality requirements, the whistle-blower will be informed of the outcome of the investigation.

2. 5. If the whistle-blower believes that his or her concern has not been dealt with properly or the wrongdoing is still ongoing, the whistle-blower should raise his or her concerns with the WEP HR and Directors.

3.    Confidentiality

WEP will treat all disclosures in a confidential and sensitive manner. The identity of the individual making the allegation will be kept confidential so long as it dies not hinder of frustrate any investigation. However, the investigation process may require the individual making the disclosure to provide a statement as evidence.

4.      Non- Retaliation

WEP is committed to protecting whistleblowers from any form of retaliation. Any employee found to have engaged in retaliation against a whistleblower will be subject to disciplinary action, up to and including termination of employment.

5.    Reporting externally

If, on conclusion of the procedure in section 2, the whistle-blower reasonably believes that appropriate action has not been taken, he or she should report the matter to one of the following bodies:

• • Relevant Regulatory Authority
  • Registrar of Societies
    
    

6.    Safeguards

WEP does not condone any frivolous or malicious complaints. WEP reserves the right to take action against those give false or misleading information. If the allegation of misconduct has been made in good faith but it is not confirmed by the investigation, no action will be taken against the whistle-blower. However, individuals who make accusations which are frivolous, malicious or for personal gain, WEP will take appropriate actions which may include disciplinary action for employees and reporting the matter to the police.

7.    Queries

For any query, please contact WEP at whistleblow@watsonep.com.sg .