1. CONFIDENTIALITY

The protection of confidential business information and trade secrets is vital to the interests and success of the Company. Confidential information includes a non-public information that might be of use to competitors or harmful to the Company if disclosed. Examples of confidential information include, but not limited to the following:

• Information concerning Company’s business;
• Financial Information;
• Bidding/ Marketing Strategies;
• Potential acquisitions;
• Pending business partnerships; and
• Pending projects and proposals

Employees should maintain the confidentiality of information entrusted to them, except when disclosure is  authorized  or  legally  mandated.  Employees  who   improperly  use or  disclose  trade secrets  or confidential business information will be subjected to disciplinary action, up to and including immediate dismissal, and possibly even legal action.

2. ASSETS AND RESOURCES

 No employee may remove from the Company’s premises any document, files, computer printouts, notes or correspondences unless the employees’ daily responsibilities require them to and such removal has been approved in advance by  their Departmental/ Function Head.   During and after the course of employment, all correspondences, notes, reports, literature, customer name cards, faxes and communications of any kind arising from the business of the Company shall remain the property of the Company and the employees acquire no rights of personal possession of such materials.

3. CONFLICT SITUATIONS

All employees shall not  at any time during their service with the Company either directly or indirectly (without prior written consent from the Company) engage or interest themselves, whether for reward or gratuitously, in any work or business other than that relating to their duties in the Company or undertake any office  notwithstanding  that such engagements or interest  may interfere  with  the performance  of their duties in the Company.

4. GIFTS  AND BENEFITS

Employees must not  accept or give any gift, hospitality, or other personal benefit from or to any third party which is likely to influence (or which other people may think likely to influence) their judgment or conflict with their duties to any customer/ vendor/ subcontractor.

Employees may consider accepting voluntarily only if:

a)    the acceptance will not influence their judgment

b)     they will not feel obliged to do something in return for the offerer;

c)     they are able to openly discuss the acceptance without reservation; and/or

d)     the nature of the advantage is such that refusal could be seen as being unsociable or impolite

It is mandatory for all employees to report the receipt of gifts and benefits to their immediate superior or the CFO.

Employees shall not  be engaged in any employment (whether for remuneration or otherwise) without the prior written approval of their Department Head and CEO,  nor participate in any activities which are against the Company’s interests or which will affect their performance at work.

6. COMMUNICATION WITH MEDIA

Employees are prohibited from  making any statements to the media concerning the business of the Company without the prior written authorisation of the Company. Any request from the media must be referred to the Corporate Office.

7. PERSONAL INTERVIEWS

All employees (other than authorised personnel) are not allowed to correspond with the media, whether using the Company’s email or otherwise. This may include, but is not limited to, the following:

• Airing their view to the media / press via writing through social media platforms
• Providing leads (interesting sights / stories) and human-interest stories to the media

8. INTERNET  ACCESS POLICY

The use of Company internet is intended to facilitate work efficiency. Surfing of any website and usage of social chat sites is strictly prohibited for non-work related matters. The use of Company email account is strictly for work purposes.

9. SOFTWARE VIRUS POLICY

All employees are responsible to take necessary actions to make sure their computers are virus free. The employee is required to update the virus definition of his/her installed anti-virus software as and when required. A full virus scan should be performed at least once a week. Auto-protect feature should be enabled at all times.

10. CHANGE OF PERSONAL RECORDS

Employees are responsible for notifying the Company of any change of address, telephone number, educational achievements, marital status, dependants, citizenship, etc. during their employment.

11. DRESSING AND APPEARANCE

Proper attire has to be observed during office hours. Dress and appearance requirements may be varied by his/her position, working  environment and business situation. Smart casual dress code is allowed but sloppiness is not tolerated.

12. SAFETY

In the interest of the employees’ safety, any unsafe practice or condition that may lead to an accident must be reported to their immediate supervisor or the Administration Department. Proper safety attire must be observed at all times when working at the project site. In the event that employees are injured during the course of  their work,  report the incident to  their  Department Head immediately so that appropriate actions can be followed-up.

13. STAFF DISCIPLINE

In the event that an employee misconducts himself/herself at work, the Company will try to counsel and help employee to correct and improve themselves. The Company will only take disciplinary action when corrective measures failed.  Examples of inappropriate and unacceptable behavior include: 

• Gambling at the Company’s premises, with/without stakes.
• Sleeping on the job or leaving the workplace without authorisation.
• Insubordination or disobedience the superior by refusing to carry out reasonable instructions.
• Making threats of violence towards anyone or provoking a fight on Company premises.
• Committing theft, fraud or dishonesty in connection with the Company’s and other colleagues’ property.
• Intentionally slowing down  or disrupting the work or activities of the Company and influencing others to do so.
• Threatening, provoking, assaulting,  abusing, coercing other colleagues or interfering with the work of other colleagues.
• Obtaining leave or absence from work by false pretenses.
• Criminal misconduct, either on or off Company premises.
• Immoral or indecent conduct on Company premises.
• Demanding, offering or accepting bribes or any illegal gratification.
• Supplying  incorrect  information  or  documents  to  the  Company in  the  course  of  his/her application for employment

This list is intended  as an example only,  and is not  intended to include all acts / behaviours that are considered inappropriate and unacceptable.

14. WHISTLE  BLOWING

Our Company believes in practicing honesty and integrity in fulfilling its responsibility, while complying with  all  applicable  laws  and regulations.  In the same spirit,  our  Company expects our employees  to make known  any act of violation or  suspected violation. It is the Company’s policy to encourage all employees  to report any possible improprieties  in  matters of financial reporting or other matters that they may encounter to the Company.

14.1 Scope of Policy

This policy applies to all employees of APAC Realty Limited (“the Company”), including full-time, part- time and contract employees and those of its local and overseas subsidiaries, and associates (the “Group”).

The Audit Committee shall be responsible for the maintenance, regular review and updating of this policy. Revisions, amendments and alterations to this policy can only be implemented after approval by the Audit  Committee  and the Board of Directors.  Changes will be notified  in writing  to all employees when these occur

14.2 Purpose

14.2.1   This policy aims to  provide an avenue for employees to  raise concerns about wrongdoing, malpractice or Improper Accounting Activity within the Company and the Group which they may become aware of  and to  provide  reassurance  that they will  be  protected from  reprisals, victimization or any retaliatory Action for whistle-blowing made in good  faith and without malice.

14.2.3   This policy is intended to cover all concerns that could have an adverse impact on the Company or the Group, or both,  such as actions that:-

• may lead to incorrect financial reporting;
• are unlawful;
• are not in line with a legal obligation of a Company or Group policy or both;
• may pose danger to the health and safety of an individual;
• may damage or cause potential damage to the environment;
• amount to professional or ethical malpractice;
• deliberately conceal serious wrongdoings or malpractices;
• may pose serious breach of fundamental internal control;
• otherwise amount to serious improper conduct;
• deliberately conceal information tending to show any of the above;
• abuse of Authority for Personal Gain; or
• any conflict of interest in any activity that is, or appears to be, opposed to the best interest of the Company

 The above list is not exhaustive. 

14.2.4  Some examples of “Improper Accounting Activity” are:

• Actual or suspected fraud, including deliberate errors in preparing evaluation or review of any financial statements of the Company or the Group or both;
• Actual or suspected error, including deliberate error in recording and maintenance of the financial records of the Company or the Group or both;
• Actual or suspected deficiencies in or non-compliance  with the Group’s internal  controls and procedures; and
• Actual  or  suspected misrepresentation  by  an officer  or  auditors  regarding   a matter contained  or  required  to  be contained  in  the Company or  the Group or  both  financial records, reports or audit reports.

14.3 Policy

The Company is committed to the highest standards of ethical and legal business conduct. In line with this  commitment  and  the  Company’s  commitment  to  open  communication  and  strong corporate governance, this  policy  provides  an avenue for  employees  to  raise  concerns  about wrongdoing, malpractice or Improper Accounting Activity within the Company or the Group when they become aware and ensure that:

(i)   independent investigations are carried out in an appropriate and timely manner,

(ii)   appropriate action is taken to  correct the weaknesses  in internal controls and policies which allowed the perpetration of fraud or misconduct or both,  and to prevent a recurrence, and

All employees within the Company and the Group are encouraged to report any wrongdoing, malpractice or Improper Accounting Activity that they reasonably believe has taken place, is taking place or will take place, to the committee appointed by the Company to receive such reports. The contact details of the committee are set out  in Section 14.5  (Procedures) below. Such reporting is commonly known  as “Whistle Blowing”.

14.4 Safeguards

Safeguards to be provided in the implementation of this policy are as follows:

(a)  No Harassment, Victimization or Retaliatory Act

Harassment, victimization  of  or  Retaliatory  Action  against  the complainant  will  not  be tolerated and appropriate steps will be taken to ensure the complainant suffers no detriment or retaliation as a result of raising concerns in accordance with this policy.

(b) Confidentiality

Every effort will be made to protect the complainant’s identity, if so requested, so long as it is compatible with a proper investigation. However, it is important to be aware that It may be necessary to  reveal the identity of the complainant, to  assist in investigations under certain circumstances or where the Company or the Group is required by law to make sure disclosure.

14.5 Procedures

14.5.1  Procedures for handling Complaints

The procedures for the receipt, retention and treatment of a Complaint are set out below and shall be fully complied with.

14.5.2   Submission of Complaints

Every Complaint shall be made in person or in writing and shall lodge the Complaint to any one of the independent directors.

The complainant must provide his/her particulars as follows: (a) Name

(b) Department/Company

(c) Contact Number and Email Address if available

The Complainant will not be attended to if the above-mentioned particulars are not stated. This policy requires employees to  put  their names to  allegations because appropriate follow-up questions and investigations may not  be possible,  unless the source of  the information is identified.

All complaints made shall include particulars and relevant information disclosing the identity of the Complainant.  In order to aid the review and investigation of complaints, a complainant shall disclose his identity when submitting Complaints and the identity of a complainant, so disclosed, shall be kept strictly confidential save where:

14.5.3.1      the identity of the complainant, in the opinion of the Company’s Board is material to any investigation;

14.5.3.2      it is required by law, order or discretion of any court,  regulatory body  or stock exchange;

or

14.5.3.3      the Company’s Board is of the opinion that it would be in the best interests of the Company or the Group to do so.

14.5.4   Determination by the Audit Committee

Upon  receipt of any Complaint, the AC may:-

(a)     Conduct its own investigation or review;

(b)     Instruct the Internal Auditor to conduct further investigations or review;

(c)     Instruct the relevant management to take such remedial action as it deems appropriate;

(d)     Engage such third partied as the AC may determine, to take remedial, to commence or conduct further investigations or review, as deem appropriate;

(e)     Report the matter to the authorities if there is reason to believe  that a crime  has been committed; and/or

(f)      Take any other action as the AC may determine in the best interests of the Group.

14.5.5   Review and Investigation of Complaint

In the event that the AC conducts its own investigation or review, the AC shall:-

(a)     review and investigate the Complaint;

(b)     inform complainant of the likely timeline for a final response;

(c)     recommend any remedial or legal action to be taken, where necessary; and

(d)     notify complainant of actions take or reason(s) should it be decided that no action is to be taken

14.5.6   Abuse of Policies and Procedures

All  Complaints should be made in good   faith with reasonable grounds for  believing that a wrongdoing, malpractice or an Improper Accounting Activity has taken place, is taking place or will take place. Only upon  the determination of the Audit Committee, may any action be taken against any employee who  has made a complaint frivolously, maliciously, in bad faith, for personal gain, making an allegation knowing it to be untrue or unfounded, or otherwise an abuse of the policies and procedures herein. Company reserves the right to take such action as the Audit Committee deems appropriate against any such employee including but  not  limited to disciplinary action.