Whistleblowing Policy & Procedure

  1. Purpose & Scope

    The REIT Manager and Property Managers (the "Group") do not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by staff in the course of their work. This Whistleblowing Policy (the "Policy") is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences. 

    Employees and outside parties, such as suppliers, customers, contractors and other stakeholders, may use the procedures set out in the Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, insider trading, collusion with competitors, serious breaches of Group policy, unsafe work practices or any other matters involving fraud, corruption and employee misconduct.

    The Policy allows for reporting by employees or outside parties of such matters to the Internal Audit Division of Cuscaden Peak Investments Pivate Limited ("CPI"), without fear of reprisal, discrimination or adverse consequences, and also permits the Group to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.

    However, while the Policy is meant to protect genuine whistleblowers from any unfair treatment as a result of their report, it strictly prohibits frivolous and bogus complaints. The Policy is also not a route for taking up personal grievances. These should continue to be taken up directly with the Management.

     

  2. Reporting Mechanisms

    All employees and outside parties are encouraged to put their names to their allegations. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided. All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.

    Concerns may be raised verbally or in writing. As it is essential to have all critical information in order to effectively evaluate and investigate a complaint, the report made should provide as much detail of the incident. The complaint should include details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible, and contact details, in case further information is required.

    The Receiving Officer is Head, Internal Audit Division of the CPI Group. The contact details of the Receiving Officer are as follows:

     

    Address:  Bridge+, 79 Robinson Road, #07-01, CapitaSky, Singapore 068897 
    Hotline  :  +65 6631 8920
    Email    :  whistleblow@cuscaden.com.sg


    Complaints raised to other parties within the Group will be directed to the Receiving Officer, who is responsible for maintaining a centralized repository of all reported cases and ensuring that issues raised are properly resolved. All matters reported will be reviewed within a reasonable timeframe, and after due consideration and inquiry, a decision will be taken on whether to proceed with a detailed investigation. Guidance/direction may be sought from the Chief Executive of the sponsor of PARAGON REIT, CPI (the "Sponsor") and the Chief Executive of the REIT Manager on appropriate action. All complaints received by the Receiving Officer including recommended action (if any) will be reported to the Chairman of the Audit and Risk Committee. For complaints relating to the respective senior management and/or Chief Executive of the Group, the matter will be escalated to the Board as well, for their guidance. Where the complaints relate to the senior management of the Sponsor, the Chairman of the Sponsor's Board would be duly notified.

     

  3. Safeguards

    The Group prohibits discrimination, retaliation or harassment of any kind against a whistleblower who submits a complaint or report in good faith. If a whistleblower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the Chairman of the Audit and Risk Committee. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.

    At the appropriate time, the party making the report/complaint may need to come forward as a witness. If an employee or outside party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. If, however, an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the outside party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.

     
  4. Handling of Complaints

    The Receiving Officer, may, in consultation with the Chairman of the Audit and Risk Committee direct the complaint to the relevant operating unit or department best placed to address it, or lead the investigation to ensure prompt and appropriate investigation and resolution. All information disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.

    The Group reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.

    If, at the conclusion of an investigation, the Group determines that a violation has occurred or the allegations are substantiated, effective remedial action commensurate with the severity of the offence will be taken.

     
  5. Modification

    The Group may modify this Policy to maintain compliance with applicable laws and regulations or accommodate organizational changes within the Group.