WHISTLEBLOWING POLICY

TRS Forensics Pte Ltd, TRS Forensics Sdn Bhd, TRS Consulting (Shanghai) Co Ltd, TRS Forensics Holdings Pte Ltd and TRS Holdings Pte Ltd (collectively known as "TRS Group" or "the Group") are committed to the highest possible standards of ethical, moral and legal business conduct and practices, and openness and accountability in all aspects of our business. In line with the above commitment, TRS has established this policy that outlines the Group’s commitment to ensure that employees and other stakeholders are able to raise genuine concerns in relation to any potential/suspected/known breach of any law, legal obligation, miscarriage of justice, or danger to health, safety and environment etc at the earliest opportunity without being subject to victimization, harassment or discriminatory treatment, and to have such concerns properly investigated.

  1. Purpose

    1. The Policy sets out the mechanism and framework by which employees, clients, contractors, consultants and any other individuals or organization who have dealings with the Group can confidently voice concerns/complaints in a responsible manner without fear of discriminatory treatment.
    2. All employees (whether permanent, contract, part-time or casual), interns, trainees, directors, shareholders, consultants, vendors, contractors, clients, external agencies or any parties with a business relationship with the Group are encouraged to report genuine concerns in relation to any potential/suspected/known breach of any law, legal obligation, miscarriage of justice, or danger to health, safety and environment etc.

  2. Defintions

    1. Whistleblowing – this occurs when an employee / other stakeholder raises a genuine concern about a potential/suspected/known dangerous or illegal activity or improper conduct that he/she is aware of through his / her work/dealings with the group.
    2. Whistleblower – The employee / other stakeholder who discloses or reports the potential/suspected/known wrongdoing.

  3. General Whistleblowing Scope

    1. The Group encourages employees / other stakeholders to make whistleblowing disclosures openly and honestly and will ensure that concerns/complaints raised will be treated independently, fairly and properly.
    2. The list of whistleblowing complaints/concerns includes, but is not limited to, potential/suspected/known acts of the following:
      • commission of fraud and/or corruption;
      • unauthorized use of the Group’s money, properties and/or facilities;
      • non-compliance with the Group’s policies and procedures and/or code of ethics;
      • negligence/malpractice;
      • disclosure of the Group’s confidential information without proper authorization;
      • commission of acts which intimidate, harass and/or victimise any members of the Board of Directors, Management or staff of the Group;
      • abuse of position;
      • involvement in conflict of interest and/or competing business;
      • commission of unlawful acts;
      • exposure of Group properties, facilities and/or staff to the risks of safety and security;
      • failure to meet the professional standard; and
      • any other detrimental wrongdoing.
    3. All whistleblowing disclosures made under this Policy will be dealt with in a confidential manner.
    4. The Whistleblower may identify himself/herself or if he/she prefers, to remain anonymous when reporting potential/suspected/known misconduct, wrongdoings, corruption, fraud, waste and/or abuse.
    5. Disclosures received under anonymity will only be considered under strict conditions and with the provision of comprehensive information/details, to prevent invalid malicious reporting, poison letters, exploitation and victimization.
    6. The Whistleblower should be able to provide the disclosure in writing, together with information regarding the type of activity or conduct, the identity of the person(s) suspected/known as being involved, when it occurred and who was affected.

  4. Reporting Channel

    1. Any disclosure of improper conduct/complaint should initially and promptly be made by the Whistleblower through the communication channels as set out below:
      Designated Person:  Tan Swee Wan
      Designation:  Chief Executive Officer
      Email:  tansweewan@trsforensics.com

  5. Confidentiality & Protection

    1. Upon making the disclosure in good faith:
      1. The Whistleblower will be protected from any reprisal within the Group as a direct consequence of the disclosure. (‘Reprisal’ includes disciplinary measures, demotion, suspension or termination of employment or service).
      2. Any form of retaliation against individuals who have reported a wrongdoing or who have facilitated with the investigations is a breach of the principal obligation of all staff members to uphold the highest values and integrity.
      3. The Whistleblower’s identity shall be protected i.e. kept confidential unless otherwise required by law or for purposes of any proceedings by, against or involving the Group.
      4. The identity and personal information of the Whistleblower and the alleged wrongdoer may be revealed to persons involved in the investigations or any other process.
    2. Protection under paragraph 5.1 above will be accorded by the Company only when the Whistleblower satisfies all the following conditions:
      1. The disclosure is done in good faith;
      2. The information provided in the whistleblowing disclosure is true to the best of the Whistleblower’s knowledge; and
      3. The disclosure is not made for personal gain or interest.
    3. The Whistleblower and the alleged wrongdoer will be treated fairly and in accordance with the Group’s policies and all applicable laws. The Whistleblower will be informed of the status of his disclosure and the alleged wrongdoer will be given an opportunity to respond to all allegations at an appropriate time.
    4. The Group views seriously any false, malicious or defamatory allegation. This can be considered as gross misconduct where appropriate disciplinary action may be taken by the Group.
    5. Suppliers / Vendors of the Group and members of the public who become a Whistleblower will also be protected by the Group as to his / her / its identity subject to satisfying all conditions in paragraph 5.2 above.

  6. Investigation Procedure

    1. Upon receipt of the whistleblowing disclosure, the Designated Person shall set up an investigating team (“Investigators”) to conduct an investigation on the issue/concern raised.
    2. The progress of the investigation shall be reported to the Designated Person periodically.
    3. Upon completion of the investigation, the Investigators shall submit their full report together with recommendation to the Designated Person. The Designated Person will make a decision, based on the report and recommendations, on the appropriate actions to be taken.
    4. Actions mandated by the Designated Person shall be carried out accordingly.

  7. EFFECT OF NOTICE AND CHANGES TO NOTICE

    1. The Group reserves the right to update this Policy at any time. You may determine if any such update has taken place by referring to the date on which this Policy was last updated.

Effective: 20 November 2020

Last Updated: 20 November 2020

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