The Trustee-Manager adheres to the highest ethical standards and complies with all applicable laws, regulations and other legal requirements. In support of its values and to ensure that employees and any other persons can raise concerns in the conduct of the Trustee-Manager's business without fear of reprisal in a transparent and confidential process, the Trustee-Manager has adopted a whistleblowing policy.

The Policy

Subject to all applicable laws and regulations, this policy relates to and governs the handling of complaints, reports and regarding potential:

• fraud;
• corruption, bribery or blackmail;
• criminal offences;
• failure to comply with applicable laws, rules and regulations;
• miscarriage of justice;
• misrepresentation or false statements and/or financial reporting of FSL Trust;
• non-compliance with policies of FSL;
• deliberate failure to follow/operate systems and procedures, which may put the assets or the Trust's reputation at risk;
• endangering the health and safety of an individual; and
• concealment of any of the above.

and any other potential improprieties and malpractices.

Reporting of Concerns

If a person believes reasonably and in good faith that improprieties in the conduct of the business activities of FSL and/or FSL Trust, financial reporting and other malpractices exists, then he or she should report this immediately to the senior management of the Trustee-Manager. However, if for any reason the person is reluctant to do so, then he or she should report their concerns to either:

• BDO LLP, who is the internal auditor of the Trust and an independent party who can provide the person care counselling and advice service, at +65 6828 9185. The concerns will be reported to the Trustee-Manager without revealing the identity of the whistle-blower.
• The Chairman of the Audit and Risk Committee, particularly if employees and any other persons still have concerns, or if employees and any other persons feel the matter is so serious that it cannot be discussed with any of the above, they can report suspected wrongdoings via:
  • Regular mail or other means of delivery, addressed to the corporate address of the Trustee-Manager, by which complaints may be submitted in a sealed envelope marked "Attention of the: Chairman of the Audit and Risk Committee, FSL Trust Management Pte Ltd - Private and Confidential to be opened by addressee only". The envelope will be forwarded unopened to the Chairman of the Audit and Risk Committee; and
  • Email sent directly to the Chairman of the Audit and Risk Blowing Committee at mikeggray@hotmail.com; and
  • Telephone call to the mobile number of the Chairman of the Audit and Risk Committee at 9855 0055.

Handling of Concerns

A person who has raised concerns, will be informed of who is handling the matter, how they can make contact with them and if there is any further assistance required. The Trustee-Manager will give as much feedback as possible without any infringement on a duty of confidence owed by the Trustee-Manager to someone else.

The following principles apply with respect to the handling of concerns:

• All concerns raised will be treated fairly, objectively and properly.
• The person's identity will not be disclosed without prior consent (except where disclosure obligations are required under law and regulations). Where concerns are unable to be resolved without revealing the identity of the person who raised concern, (e.g. if their evidence is required in court), FSL will enter in to a dialogue with the person as to whether and how to proceed.
• In all cases, upon receipt of the concern, the Audit and Risk Committee shall:
  • acknowledge the receipt to the person reporting the concern (where the identity has been disclosed);
  • make an initial assessment as to the prima facie merits;
  • investigate the concerns raised expeditiously, without sacrificing thoroughness
  • inform the person reporting the concern (where the identity has been disclosed) in writing of the outcome of the investigations;
  • ensure that the principles of due process and natural justice are applied.
• If the Audit and Risk Committee deems it appropriate, it may engage at the Trust's expense independent advisors, such as lawyers and accountants, unaffiliated with the Trust's lawyers or external auditors, to assist in its deliberations.
• Following the investigation and evaluation of the concern, the Audit and Risk Committee will prepare a written report on its finding, recommended disciplinary, remedial or other actions, if any.

Right of Appeal

If someone who has reported a concern remains dissatisfied with the outcome of the investigation, they have a right of appeal on the following grounds:

• they believe the procedures have not been followed properly or; and/or
• they are convinced that the decision is one which no reasonable person could have reached,

the Chairman of the Board (or the Chairman of the Audit and Risk Committee, if the whistle-blowing allegation involves the Chairman) will appoint a person to hear the appeal. This will be an external lawyer or qualified accountant not involved with the Trust and who has such experience with such matters.

No Retaliation

The Trustee-Manager will not permit any negative or adverse actions to be taken against employees or any other person who raises concerns because that person has made a report in good faith, even if such report proves to be mistaken, unless the person maliciously raises a matter he or she knows to be untrue.

Retaliation, harassment or victimisation of anyone raising a genuine concern will not be tolerated. Any act of alleged retaliation, harassment or victimisation should be reported immediately to the Chairman of the Audit and Risk Committee and will be promptly investigated and resolved.