Investors

Statement of Purpose & Authority

Pursuant to the Code of Corporate Governance (“CCG) coming into effect from January 1, 2007, the Audit Committee (AC) has established a policy on Whistleblowing.

This policy established procedures for:

1. the receipt, retention and treatment of complaints received by CSE Global Ltd and its group of companies (the “Company”) regarding personal conducts, accounting, internal accounting controls, or auditing matters, and
2. the confidentiality of the submission by employees of the Company of concerns regarding questionable behaviour as well as accounting or auditing matters.

Applicability of Local Laws and Regulations

The Policy applies to all Directors, officers and its employees, and any other persons or business organisations carrying out work for the Company and it covers disclosure of any concern which, in your honest, reasonable belief, suggests that wrongdoing has been committed, is in the process of being committed or is likely to be committed.

Reportable Incidents

Concerns which should be reported include, without limitation, the following:

1. use of Company funds or property for any illegal, improper or unethical purpose;
2. tampering with or destroying any Company accounting or audit-related records or documents except as otherwise permitted or required by Company records retention policy;
3. fraud or deliberate error in the preparation, evaluation, review or audit of any of the Company’s financial statements;
4. fraud or deliberate error in the recording and maintaining of the Company’s financial records;
5. corruption in the form of bribes offered or taken by employees of the Company
6. misrepresentations or false statements to or by a senior officer or accountant regarding a matter contained in the Company’s financial records, financial reports or audit reports;
7. deviation from full and fair reporting of the Company’s financial condition, results of operations or cash flows; and
8. any effort to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statement or records of the Company.
9. usage of company property for personal benefits which resulted in major opportunity costs / loss for the company.
10. disclosing confidential and proprietary information to outside parties

Safeguards for whistleblowers

What safeguards do whistleblowers have?

1. Policy Oversight
   • the Audit Committee has the responsibility of overseeing this Policy and compliance by the Company
2. Protection Against Retaliation
   • this Policy is designed to offer protection to those who disclose a complaint, provided the disclosure is made in good faith. Anyone engaging in retaliatory conduct will be subject to disciplinary action by the Company, which may include termination.
3. Confidentially
   • the Company will treat all (written) complaints in a confidential and sensitive manner. A report of a complaint will only be disclosed to persons who have a need to know basis in order to properly carry out an investigation. Your identity will not be revealed outside the knowledge of designated persons.
   • if there are any circumstances in which your identity is required to be revealed outside those designated persons, we will discuss this with you first. Under no circumstances will you find that your identity has been revealed outside these designated persons without your knowledge.
4. Untrue Allegations
   • if an employee makes an allegation in good faith, which is not confirmed by subsequent investigations, no action will be taken against the individual in making a disclosure, the individual should exercise due care to ensure the accuracy of the information. If, however, an employee makes malicious allegations, disciplinary action may be taken against the individual.

Whistleblowing Reporting & Communication Channels

Who should a disclosure be made to?

1. as a first step, concerns of an employee should be raised with the employee’s immediate line manager. This can be done either face to face or in writing. Please make it clear that you are raising your concern as part of the whistleblowing procedure.
2. however, if the employee does not feel comfortable to report to the line manager or Management structure, then he or she should address his/her concerns in writing directly to the Audit Committee Chairman or to the Group Internal Auditor.
3. once an initial disclosure has been made, the matter will be referred urgently to the Audit Committee Chairman or the Group Internal Auditor who will determine the appropriate course of action.
4. concerns may be put in writing or raised orally
5. written complaints should include:
   1. background,
   2. nature of the malpractice that is alleged
   3. relevant date where possible
   4. reasons for the concerns
   5. names of individuals against whom the allegations are made
   6. material evidence (if available)

and sent to:

The Audit Committee Chairman
CSE Global Ltd
202 Bedok South Avenue 1
#01-21
Singapore 469332
Tel: +65 6512 0333
auditcommittee@cse-global.com

OR

The Group Internal Auditor
CSE Global Ltd
c/o Suite 3.02 3
rd Floor Lot 10
Wisma BKA, Jalan Astaka U8/84
Bukit Jelutong, 40150 Shah Alam
Selangor, Malaysia
Tel: +603 7846 8580
internalauditor@cse.com.sg

Review & Monitoring

Summary details of any disclosures made under this policy will be reported to the Audit Committee every quarter. The policy will be regularly reviewed and updated.