1. Purpose

Cyclect Holdings Pte Ltd (“Cyclect”) is committed to conducting business with integrity, accountability and compliance with applicable laws and company policies.

This Whistleblowing Policy provides a channel for employees and external parties to report genuine concerns involving suspected misconduct, wrongdoing, fraud, unethical conduct, breaches of law, or serious breaches of company policy involving Cyclect.

2. Who May Report

Reports may be made by employees, suppliers, contractors, customers, business partners or other external parties, provided the concern relates to Cyclect, its personnel, business activities or operations.

3. Reportable Concerns

Reportable concerns may include, but are not limited to:

• fraud, theft, bribery, corruption or dishonest conduct;
• conflicts of interest;
• falsification of records, claims, invoices or reports;
• financial misstatement or improper accounting;
• serious breaches of law, regulation, permit or company policy;
• misuse of company assets, confidential information or personal data;
• serious workplace misconduct, harassment or discrimination;
• health, safety, security or environmental violations;
• procurement irregularities, collusion or improper supplier practices;
• retaliation against a person who raises a genuine concern;
• deliberate concealment of any of the above.

4. Matters Outside This Policy

This Policy is not intended to replace normal reporting channels for routine employment grievances, performance matters, interpersonal disputes, customer service issues, operational complaints, commercial disputes or general HR matters.

Such matters should normally be raised with the relevant supervisor, Human Resources, project lead, business unit head or responsible department, unless the matter involves serious misconduct, illegality, retaliation, concealment or a conflict of interest that makes normal channels inappropriate.

This channel is not an emergency response channel. Immediate threats to safety, life, property or public security should be reported to the appropriate emergency services or authorities.

5. How to Report

Reports may be submitted by email to:

compliance@cyclect.com

Suggested subject line:

Whistleblowing Report – Confidential

A report should include sufficient information for Cyclect to assess the matter, where available:

• nature of the concern;
• names or roles of persons involved;
• date, time and location of the incident;
• whether the matter occurred once or repeatedly;
• how the matter became known;
• whether it has been reported elsewhere;
• supporting documents, records, emails, photographs or other evidence;
• reporter’s contact details, if the reporter is willing to provide them.

6. Anonymous Reports

Anonymous reports may be submitted. However, Cyclect may be unable to properly assess, investigate or act on a report if insufficient information is provided or if clarification cannot be obtained.

Cyclect encourages reporters to provide contact details where possible, so that follow-up questions may be raised where necessary.

7. Good Faith Reporting

Reports should be made in good faith and based on reasonable grounds.

A reporter does not need to prove the concern before making a report. However, the report should not be made maliciously, knowingly falsely, without reasonable basis, for personal gain, or for the purpose of harassing, intimidating or damaging another person.

Cyclect may take appropriate action where a report is found to have been made maliciously, dishonestly, in bad faith or for an improper purpose. Cyclect reserves all rights and remedies available under law, contract or company policy.

8. Review and Handling of Reports

Cyclect may review, assess, investigate, redirect, escalate, close or take other appropriate action on a report at its discretion, based on the nature of the concern, available information, evidence, seriousness, legal requirements and business circumstances.

Cyclect does not guarantee that every report will result in a formal investigation, response, update, disciplinary action, legal action or specific outcome.

Where appropriate, Cyclect may refer or disclose the matter to relevant internal or external parties, including professional advisers, auditors, insurers, regulators, law enforcement agencies or other authorities.

9. Confidentiality

Cyclect will make reasonable efforts to maintain confidentiality, subject to operational, legal, regulatory, disciplinary, investigation, audit, insurance and business requirements.

Confidentiality cannot be guaranteed where disclosure is required or considered necessary for assessment, investigation, corrective action, legal compliance, regulatory reporting, natural justice, protection of persons or assets, or the defence of Cyclect’s rights and interests.

Reporters should also keep the matter confidential and avoid discussing the report with unauthorised persons.

10. Protection Against Retaliation

Cyclect does not tolerate retaliation against any person who raises a genuine concern in good faith or assists in a related review or investigation.

Any suspected retaliation should be reported promptly to Cyclect. Cyclect may take appropriate action where retaliation is found to have occurred.

This protection does not apply to persons who make reports maliciously, knowingly falsely, dishonestly, without reasonable basis or for an improper purpose.

11. Personal Data

Personal data submitted under this Policy may be collected, used, disclosed and retained by Cyclect for purposes including assessment, review, investigation, follow-up, corrective action, disciplinary action, legal or regulatory compliance, audit, governance, risk management, record-keeping, protection of rights and business operations.

By submitting a report, the reporter acknowledges that Cyclect may process personal data for such purposes, subject to applicable data protection requirements.

12. Policy Review

Cyclect may review, amend or update this Policy from time to time without prior notice. The version published on Cyclect’s website shall be the current public version.