WHISTLE-BLOWING POLICY

TYE SOON LIMITED
WHISTLE-BLOWING POLICY & PROCEDURE

To All Employees

Tye Soon Limited requires its directors, managers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. We must fulfill our responsibilities with honesty and integrity, and comply with all applicable laws and regulations. We should be alert to situations where honesty and integrity are compromised. In such situations, violations should be reported.

Below is a list of examples of violations:

Accounting-Related Violations

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

Non-Accounting-Related Violations

• Misappropriation of cash sales/collections;
• Misuse/abuse of petty cash;
• Unauthorized discount/giveaway/rebate;
• Falsifying/amending attendance record;
• Pilferage of stocks; and
• Abuse of authority for personal gain.
Employee Rights and Reporting Procedure

An employee has the right to report any violation. He must do it in writing and must provide the following particulars:

a. Name
b. Company/Department
c. Contact number/email address

No retaliatory action will be taken against such employee.
The report on any of the above violations, or other violations not highlighted above, is to be lodged with:

Audit and Risk Committee Chairperson
Email : whistleblowing@tyesoon.com
Confidentiality

A report of a violation or suspected violation may be submitted on a confidential basis by the complainant. Such a report will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation of the matter in question.

The identity of the employee who reported the violation might be disclosed under certain circumstances which warrant such disclosure, for example:

• Where required by law; or
• Where the Audit and Risk Committee with the concurrence of the Board of Directors is of the opinion that it would be in the best interest of Tye Soon Limited to disclose.
Handling of Reported Violations

The Audit and Risk Committee Chairperson will acknowledge the employee who made the report and confirm receipt of the report of a violation or suspected violation. All reports will be promptly investigated and appropriate action will be taken.

Complaints Register

A complaints register will be maintained by the Audit and Risk Committee Chairperson to record all complaints received together with details such as date and nature of such complaints. The Audit and Risk Committee can approve the inspection of the Complaints Register by investigation authorities upon their request.

Frivolous or Malicious Complaints

Any employee who files a frivolous or malicious complaint in bad faith will be subjected to disciplinary action, including, but not limited to, termination of employment.

Maintenance of the Policy and Procedure

The Audit and Risk Committee has the responsibility to ensure the maintenance, regular review and updating of the whistle-blowing policy and procedure. All amendments and alterations to this policy and procedure can only be effective upon approval by the Audit and Risk Committee and the Board of Directors.