WHISTLE BLOWING POLICY

Purpose and Scope

RE&S Group is committed to a high standard of compliance with the requirements of accounting , financial reporting, corporate governance, auditing, internal controls and any legislation relating thereto. The Group will not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by any staff in the course of their work. In line with this commitment, the Whistle Blowing Policy aims to provide an avenue and secure framework for all staff of the Group and external parties such as vendors, suppliers, contractors, customers and other stakeholders to report concerns about actual or suspected improprieties without fear of reprisals, victimisation or other adverse consequences for responsible whistleblowing in good faith.

The Policy is intended to promote standards of good corporate practices conforming to the guidance set out in the Code of Corporate Governance regulated by the Monetary Authority of Singapore which encourages staff to report, in confidence, possible wrongdoings and irregularities.

Reporting Mechanism

1. Authority to receive complaints

   All complaints shall be reported directly to any of the Receiving Officers as follows:

   Deputy Director, Management Office Email: shyangzheng.lim@res.com.sg
   Head, Human Resource Email: shyangzheng.lim@res.com.sg
   Chairman, Audit Committee Email: ben.yeo@res.com.sg

2. What to report

   Employees are encouraged to report:

   • Forgery
   • Any dishonest or fraudulent act
   • Misappropriation of funds, supplies, or other assets and classified documents
   • 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 improprieties which cause financial or non-financial loss to the Group or loss of the Group’s reputation
   • Discrimination on the basis of gender, race, disabilities
   • Assigning responsibilities or giving promotions based on favouritism.
   • Abuse and misrepresentation of power and authority
   • Harassment

The above list is intended to give an indication of the kind of activities and/or conduct which might be considered as "wrong-doing". In cases of doubt, the whistle-blower should speak to his or her immediate superior.

All concerns shall be reported in writing and should include specific details of the parties involved, dates or periods of time and any other information substantiating the complaint.

The Receiving Officer shall maintain a repository of all reported cases and ensure that the issues raised are properly investigated and resolved.

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 or be subjected to retaliation, retribution, discrimination or harassment. Provided that the staff is acting in good faith, it does not matter if he or she is mistaken with regards to the concern or complaint.

However, the Group does not condone bogus, frivolous, mischievous or malicious allegations. Staff(s) making such allegations will face disciplinary action in accordance with the Group's Disciplinary Procedures.

If investigations reveal that any other party making the complaint has done so maliciously and/or for personal gain, appropriate action may be taken including a report to the police.

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 anonymity, while facilitating greater communication, whistle-blowers can choose from 2 options:

1. Full disclosure:
   The whistle-blower shall disclose his or her identity to facilitate contact and communication with the Group
2. Partial anonymity:
   The whistle-blower shall provide personal details to the Receiving Officer which shall not be divulged to the Group.

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

• Where the Group 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 disclosed, the Group will inform the whistle-blower prior to the disclosure.

Concerns expressed anonymously are much less persuasive and may hinder the investigation as well as the protection of the whistle-blower's position.

Response from the Company

The Group will investigate the issues/feedback raised via the whistle blowing process but consideration will be given to these factors:

• Severity of the issues raised, having regard to the person(s) involved,
• Financial impact, reputational impact and extent of fraud proliferation.
• Credibility of the concern or information.
• Likelihood of confirming the concern or information from attributable sources.

The amount of contact between the whistle-blower and the persons(s) investigating the concern raised and information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistle-blower during the course of the investigation.

All cases shall be reviewed within a reasonable timeframe and after due consideration and inquiry, a decision shall be taken on whether a full scale investigation is warranted. Guidance and direction may be sought from the CEO who shall decide on the cases to be escalated to the Audit Committee and the Chairman of the Board of Directors. Complaints relating to fraud, breaches of corporate governance and/or to a senior executive or the CEO shall be escalated to the Audit Committee and the Chairman of the Board of Directors.

The Group reserves the right to refer any complaint to appropriate external regulatory authorities.

The Receiving Officer will communicate the findings of the investigation(s) to the offices of the President and CEO.

If the Group determines at the conclusion of the investigations that the allegations in a complaint are substantiated, effective remedial action will be taken.