COGENT WHISTLE-BLOWING POLICY

Objective

It is the desire and aim of Cogent Holdings Limited (“Cogent”) and its subsidiary companies (collectively “the Group”) to develop, promote and maintain high standards of corporate governance within the Group and in connection therewith the Whistle-Blowing Policy has been adopted.

The Policy aims to provide an avenue for employees and any person who has dealings with the Group (“Target Persons”) to raise complaints about possible improprieties within the Group and to provide reassurance that they will be protected from retaliatory actions for whistle blowing in good faith.

Policy Oversight

The Audit Committee of Cogent (“AC”), comprising all independent directors, has the responsibility of overseeing the policy. The AC has delegated the administration of the whistle blowing channels to an independent professional service firm so that the complaints can be reported in an anonymous (if so desired) and confidential manner.(herein referred to as the “Designated Party”). At the date of this Policy, the Designated Party is Yang Lee & Associates.

Channels

Target Persons may report Complaints through the following channels:

By Email : cogent@whistleblow.com.sg
By Mail : Tanjong Pagar Post Office, P.O. Box 385, Singapore 910813.

Direct to the Designated Party :

Designated Party Yang Lee & Associates
Address 10 Anson Road, #31-01
International Plaza
Singapore 079903
Contact Person Mr. Lee Dah Khang
Designation Director
Contact Number 6222 9833
Email dahkhang@yanglee.com.sg

What and How to Report

Whistle-blowers may use any of the available channels mentioned above to report their concerns.

To enable Cogent to effectively investigate your concerns, we would need the following details of the whistle-blower:

If whistle-blower is a Cogent Staff If whistle-blower is not a Cogent Staff
Name of whistle-blower
Department/Entity
Company Name
Contact Number/Email Address
Details of alleged misconduct, improper negligent or activity occurred
Information of staff involved
Time, date and location of alleged activity
Evidence of alleged activity
Other relevant details

Whistle-blowers are encouraged to put forth their names to the complaints because appropriate follow-up questions and investigations may not be possible unless the source of the information is identified. To the extent possible and permissible under the law, Cogent will make every effort not to reveal the identity of the whistle-blower.

Examples which warrant whistle-blowing

  1. Unlawful actions like corruption
  2. Inaccurate or misleading financial reporting like fraud
  3. Matters not in line with any Group policy
  4. Unhealthy or unsafe practices
  5. Environmentally damaging actions
  6. Unprofessional or unethical malpractices
  7. Sexual harassment