9/27/2017 12:00:00 AM

Whistle-Blowing Policy

Tuan Sing 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 aims to provide an avenue for employees and external parties to raise concerns and offer reassurance that they will be protected from reprisals or victimisation for whistle-blowing in good faith.

While the Whistle-blowing Policy is meant to protect genuine whistle-blowers from any unfair trearment as a result of their report, it strictly prohibits frivilous and bogus complaints.  The policy is also not a route for taking up personal grievances.

There may be circumstances where there is insufficient evidence  for the Whistle-blowing Committee ("WBC") to proceed with the investigation, particularly in situations of anonymous reporting or in cases where the reliability and / or credibility of the reported concern is questionable.

A mechanism for the submission of issues/concerns has been established which includes a dedicated secured e-mail address allowing whistle-blowers to contact the WBC and the Audit and Risk Committee Chairman directly, and in confidence and his/her identity will be protected from reprisals within the limits of the law.

Assisted by the WBC, the Audit and Risk Committee (“ARC”) addresses issues/concerns raised and arranges for investigation and/or follow-up of appropriate action.  The ARC reports to the Board any issues/concerns received by it and the WBC, at the ensuing Board meeting.  Should the ARC or WBC receive reports relating to serious offences, and/or criminal activities in the Group, they and the Board have access to the appropriate external advice where necessary.  Where appropriate or required, a report is made to the relevant governmental authorities for further investigation/action.

The WBC consists of:
•    CEO
•    CFO
•    Company Secretary

The WBC is empowered to:

•    look into all issues/concerns relating to the Group (except for those directed specifically to
      or affecting any member of the WBC which are dealt with by the ARC);
•    make the necessary reports and recommendations to the ARC or the Board for their review
     and further action, if deemed required by them; and
•    have access to the appropriate external advice where necessary and, where appropriate or
     required, report to the relevant governmental authorities for further investigation/action.

Mechanism for Submission of Issues/Concerns
1.    For issues/concerns relating to all matters (except those concerning any member of the WBC), the employee or any other persons may raise the issue with or send his/her concern to:

a.    Any member of the WBC via telephone communication at (+65) 6223 7211.
b.    Email address:, attention to “The TSH Whistle-
       Blowing Committee”
c.    Mail address: 9 Oxley Rise #03-02 The Oxley Singapore 238697, attention to “The
       TSH Whistle-Blowing Committee”

2.    For issues/concerns relating to or concerning any member of the WBC, the employee or any
other persons may raise the issue with or send his/her concern to:

a.    The Audit and Risk Committee Chairman, Mr Choo Teow Huat Albert, via telephone 
       communication at (+65) 68399217
b.    Email address:, attention to “The Chairman of TSH
       Audit and Risk Committee”
c.    Mail address: c/o Tuan Sing Holdings 9 Oxley Rise #03-02 The Oxley Singapore
      238697, attention to “The Chairman of TSH Audit and Risk Committee”

Important Notes to Whistle-Blowers
1.    The identity of whistle-blowers will be kept strictly confidential and not be disclosed to any person(s) other than members of the relevant Committees.
2.    Exceptional circumstances under which information provided by the whistle-blower could or would not be treated with strictest confidentiality include:

a.    Where the Group is under a legal obligation to disclose information provided
b.    Where the information is already in the public domain
c.    Where the information is given on a strictly confidential basis to legal or auditing 
       professionals for the purpose of obtaining professional advice
d.    Where the information is given to the police or other authorities for criminal

In the event that the WBC or the ARC, as the case may be, are faced with a circumstance not covered by the above, and where the whistle-blower’s identity is to be revealed, the investigator will endeavour to discuss this with the whistle-blower first.

3.    No action of any kind will be taken by the Company against a whistle-blower nor will his or her position in the Group be adversely affected by his/her merely raising the concerns/issues or making an allegation against a company official; provided always that he or she raises the concerns/issues or allegations in good faith and without malice and has reasonable ground believing them to be true.

4.    The WBC or the ARC (as appropriate) will take all reasonable measures to ensure that whistle-blowers will be protected from any plausible reprisals by any company officials or fellow colleagues.

5.    A malicious or frivolous complaint or allegation made by an employee against company official or fellow colleagues, however, may result in the Company, after proper investigation, taking disciplinary action against him or her.

6.    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 Group will consider anonymous reports, but concerns expressed or information provided anonymously will be investigated on the basis of their merits.

7.    The earlier the concern is raised the easier it is for the Group to take action.