WHISTLE BLOWING POLICY

Objective:

1. RE&S is committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements, and any legislation relating thereto. In line with this commitment, the Whistle-blowing Policy (the “Policy”) aims to provide an avenue for staff and external parties (such as vendors) to raise concerns and offer reassurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
2. The Policy is intended to conform to the guidance set in the Code of Corporate Governance, regulated by the Monetary Authority of Singapore which encourages staff to raise concerns, in confidence, about possible irregularities.
3. Promote standards of good corporate practices
4. Provision of proper avenues for staff to raise concerns about actual or suspected improprieties in matters of financial reporting or other matters and receive feedback on any actions taken
5. Assure staff that they will be protected from reprisals or victimisation for whistle-blowing in good faith.

Eligibility:

This policy applies to all staff of RE&S.

Procedures:

1. Authority to receive complaints

   All complaints shall be reported directly to any of the following Senior Management:

   Chief Operating Officer, Management Office Email: shyangzheng.lim@res.com.sg
   Head, Human Resource Email: Voice@res.com.sg
   Chairman, Audit Committee Email: ben.yeo@res.com.sg

2. What to report

   Staff are encouraged to report

   • Fraud, misappropriations and other irregularities, or such suspected acts that come to their knowledge
   • Any dishonest or fraudulent act
   • Misappropriation of funds, supplies, or other assets
   • Impropriety in the handling or reporting of money or financial transactions
   • Profiteering as a result of insider knowledge of the company activities;
   • Disclosing confidential and proprietary information to outside parties;
   • Accepting or seeking any reward from contractors, vendors, or persons providing services/materials to the company in connection with influencing the outcome of contracts
   • Unauthorised destruction, removal, or inappropriate use of records, furniture, fixtures and equipment
   • Intentional provision of incorrect information to public bodies
   • Conduct which is an offence or breach of law
   • Serious conflict of interest without disclosure
   • Any other serious improper matters which cause financial or non-financial loss to the Company or the Company's reputation
   • Irregularities concerning an employee's moral, ethical or behavioural conduct
   • Favouritism in the workplace such as assigns responsibility or gives promotions based on favouritism.

The above list is intended to give an indication of the kind of conduct which might be considered as “wrong-doing”. In cases of doubt, the whistle-blower should speak to his or her immediate superior or our independent Director.

Protection against reprisals

If the staff raises a genuine concern under this Policy, he or she will not be at risk of losing his or her job or suffering from retribution or harassment as a result. Provided that the staff is acting in good faith, it does not matter if he or she is mistaken. However, the Company does not condone frivolous, mischievous or malicious allegations. Staff(s) making such allegations will face disciplinary action in accordance with the Company's Disciplinary Procedures.

Confidentiality

The Company encourages the whistle-blower to identify himself or herself when raising a concern or providing information. All concerns will be treated with strict confidentiality. In order to maintain caller anonymity, while facilitating greater communication, whistle-blowers can choose from 2 options:

1. Full disclosure:
   Where the whistle-blower chooses to provide his or her identity to facilitate contact and communication with the Company or
2. Partial anonymity:
   Where the whistle-blower provides personal details to the any of the Senior Management – Chief Operating Officer, Head Of Human Resources, at no time will these details be divulged to the Company.

Exceptional circumstances under which information provided by the whistle blower could or would not be treated with strictest confidentiality include:

• Where the Company is under a legal obligation to disclose the information provided.
• Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; where the information is given to the Police or other authorities for criminal investigation.
• Where the whistle-blower's identity is to be revealed, we will endeavour to discuss this with the whistle-blower first.

Concerns expressed anonymously are much less persuasive and may hinder investigation work as it is more difficult to look into the matter or to protect the whistle-blower’s position. Accordingly, the Company will investigate anonymous reports on the basis of their merits.