Whistle Blowing Policy

1. Scope

This policy is applicable to all employees of Best World ("the Company"), including those employed by overseas subsidiaries.

2. Purpose

Consistent with the Company’s dedication to maintaining high ethical, moral, and legal business practices as well as promoting open communication, this policy is designed to give employees a safe way to voice concerns. It ensures that they are protected from any retaliation or victimization for whistleblowing done in good faith.

3. Policy

The Whistle Blowing Policy covers serious concerns over actions that can negatively impact the Company, such as

  1. Any dishonest or fraudulent act

  2. Misappropriation of funds, supplies or other assets

  3. Impropriety in handling or reporting of money or financial transactions

  4. Profiteering because of insider knowledge of company activities,

  5. Disclosing confidential and proprietary information to outside parties

  6. Disclosing to other person securities activities engaged in or contemplated by the company

  7. Accepting or seeking anything of material value from contractors, vendors or persons providing services/materials to the Company

  8. Destruction, removal, or inappropriate use of records, furniture, fixtures and equipment

  9. Acts that are not in line with Company’s policy or interest; or constitute severe improper conduct including but not limited to threats to an individual’s health and safety.

Matters concerning personal promotion or remuneration benefits are excluded from the Whistle Blowing Policy and should be addressed with the employee's immediate supervisor or the Human Resources manager. Whistleblower reports related to these issues will not be considered.

4. Safeguards

4.1 Harassment or Victimization

Harassment or victimization of the whistleblower shall not be tolerated. Those found to have taken reprisal actions or victimized the whistle blower shall face disciplinary action, including the possibility of dismissal.

4.2 Anonymous Allegations

Employees can submit their disclosures anonymously, but it is preferred that the name of the whistleblower be provided so that the appropriate follow-up questions and investigations may be undertaken and subsequent discussions can be arranged.

4.3 Malicious Allegations

Disciplinary action may be taken against any person(s) making malicious allegations.

4.4 Protecting the Whistleblower

During the assessment of the disclosure, measures shall be taken to:

  • Protect the identity of the whistleblower
  • Promptly address any worries about retaliation for reporting a concern.
  • Keep the whistleblower updated on the situation.

5. Procedure

5.1 Reporting

The Whistle Blowing Policy is intended for significant and delicate matters. To clarify, any potential loss amounting to Singapore Dollars Twenty Thousand (S$20,000) or greater is deemed material.

Reports can be submitted by emailing the Whistle Blowing Report to an independent HQ function at compliance@bestworld.com.sg.

You may also mail the Whistle Blowing Report to the following address if required. Please indicate the name of the party whom you wish to bring attention to.

Mailing address
Best World International Limited
20W Pasir Panjang Road #08-28 Mapletree Business City, Singapore 117439

5.2 Evidence

Although the employee is not expected to prove the truth of an allegation, the employee needs to demonstrate to the person contacted that there are sufficient grounds for concern.

5.3 How Disclosures are Handled

The response will depend on the concern's nature; initial inquiries will assess the need and type of investigation. If required, an independent investigation will be conducted. The Board of Directors will receive a summary report with the disclosure, investigation findings, and follow-up actions.

Whistleblower disclosures are compiled and reported to the Board of Directors every six months.

5.4 Updates for Whistleblower

Disclosures will be acknowledged within 7 business days. Whistleblowers will be informed of the actions taken if they provided contact details, subject to legal constraints.

5.5 Further Information

The extent of interaction between the whistleblower and the investigating committee will vary based on the issue's nature and how clear the provided information is. Additional details might be requested from the whistleblower.