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Cyclect Whistleblowing Policy

Effective Date: 1 January 2026
Policy Owner: Compliance
Applies To: Cyclect Holdings Pte Ltd and applicable Cyclect group entities

1. Policy Statement

Cyclect Holdings Pte Ltd and its related companies, subsidiaries and business units, collectively referred to as “Cyclect”, are committed to conducting business with integrity, accountability, transparency and compliance with applicable laws, regulations and company policies.

This Whistleblowing Policy provides a safe and proper channel for employees and external parties to report actual or suspected misconduct, wrongdoing, fraud, unethical conduct or breaches of law or company policy.

The objectives of this Policy are to:

  1. encourage the reporting of genuine concerns in good faith;
  2. provide a reliable process for receiving, reviewing and investigating reportable concerns;
  3. protect whistleblowers from retaliation where reports are made in good faith;
  4. ensure that appropriate corrective, disciplinary, legal or governance actions are taken where required; and
  5. support Cyclect’s commitment to ethical business conduct, responsible governance and lawful operations.

Cyclect will treat all whistleblowing reports seriously and will handle them with appropriate confidentiality, fairness and objectivity.

2. Scope and Application

This Policy applies to:

  1. all directors, officers and employees of Cyclect, whether permanent, temporary, contract, part-time or seconded;
  2. interns, trainees, consultants, contractors and agency personnel working with or for Cyclect;
  3. suppliers, subcontractors, service providers, business partners, customers and other external parties who have dealings with Cyclect; and
  4. any person who becomes aware of a reportable concern involving Cyclect, its personnel, business activities or operations.

This Policy applies across Cyclect’s operations, including offices, workshops, project sites, customer facilities, overseas business activities and group entities where Cyclect has management control.

Where Cyclect does not have management control over a joint venture, associate, partner or project entity, Cyclect will encourage the adoption of equivalent whistleblowing principles where appropriate.

3. Reportable Concerns

A reportable concern refers to any actual or suspected misconduct, wrongdoing, breach, unethical conduct or improper activity involving Cyclect.

Examples include, but are not limited to:

  1. fraud, theft, cheating, misappropriation or dishonest conduct;
  2. bribery, corruption, kickbacks or improper payments;
  3. conflict of interest or failure to declare a conflict of interest;
  4. falsification of accounts, records, claims, invoices, reports or documents;
  5. fraudulent accounting, financial misstatement or improper financial reporting;
  6. breach of applicable laws, regulations, permits or licensing requirements;
  7. breach of Cyclect’s policies, procedures, Code of Conduct or delegated authority limits;
  8. misuse of company assets, funds, information, systems or property;
  9. unauthorised disclosure or misuse of confidential, commercial or personal data;
  10. harassment, discrimination, bullying or serious workplace misconduct;
  11. health, safety, security or environmental violations;
  12. procurement irregularities, bid-rigging, collusion or unfair supplier practices;
  13. retaliation against a whistleblower or any person assisting in an investigation;
  14. deliberate concealment of any of the above.

This Policy is not intended to replace normal channels for:

  1. routine employment grievances;
  2. performance management issues;
  3. interpersonal workplace disputes;
  4. customer service feedback;
  5. operational complaints;
  6. commercial disputes;
  7. 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 reporting channels inappropriate.

4. Whistleblowing Channels

Reports may be made to Compliance through the following channels:

Email: compliance@cyclect.com
Subject line: Whistleblowing Report – Confidential

Postal Address:
Compliance
Cyclect Holdings Pte Ltd
33 Tuas View Crescent
Singapore 637654

A whistleblowing report should include as much relevant information as possible, including:

  1. the name, department, company or organisation of the person making the report, unless the report is anonymous;
  2. contact details for follow-up, where the whistleblower is willing to provide them;
  3. the relationship of the whistleblower to Cyclect;
  4. the names and roles of the persons involved;
  5. the nature of the concern;
  6. the date, time and location of the incident or conduct;
  7. whether the incident occurred once or repeatedly;
  8. how the whistleblower became aware of the matter;
  9. whether the matter has been reported to anyone else;
  10. any supporting documents, emails, messages, photographs, records or other evidence.

Whistleblowers are encouraged to provide their name and contact details so that Cyclect can seek clarification and conduct a more effective review. Anonymous reports will be considered, but Cyclect’s ability to investigate may be limited if insufficient information is provided.

5. Handling, Review and Escalation of Reports

All whistleblowing reports will be received and initially reviewed by Compliance.

Depending on the nature, seriousness and sensitivity of the matter, Compliance may escalate the report to:

  1. the Chief Executive Officer;
  2. the Board of Directors;
  3. external legal counsel, forensic advisers, auditors or investigators;
  4. law enforcement or regulatory authorities, where appropriate.

Where a report involves Compliance, the Chief Executive Officer, a director, senior management, or any person who would ordinarily receive or review the report, that person must be excluded from the review, assessment and investigation process.

Cyclect may conduct an initial assessment to determine:

  1. whether the report falls within this Policy;
  2. whether sufficient information has been provided;
  3. whether urgent action is required;
  4. whether there is any immediate risk to safety, assets, data, evidence or legal compliance;
  5. whether internal or external investigation is appropriate;
  6. whether the matter should be escalated to the Chief Executive Officer, the Board, legal counsel, regulators or law enforcement.

Cyclect will determine the appropriate investigation process based on the facts, severity, sensitivity and evidence available.

6. Confidentiality

Cyclect will use reasonable efforts to protect the confidentiality of the whistleblower’s identity and the information provided.

Information relating to a whistleblowing report will be disclosed only on a need-to-know basis, including where disclosure is necessary for:

  1. review, investigation or resolution of the report;
  2. escalation to Compliance, the Chief Executive Officer or the Board;
  3. protection of persons, assets, systems or evidence;
  4. disciplinary, legal, regulatory or enforcement action;
  5. compliance with applicable laws, regulations, court orders or lawful requests from authorities;
  6. obtaining advice from legal counsel, auditors, insurers, investigators or professional advisers.

Cyclect cannot guarantee absolute confidentiality where disclosure is required by law, regulation, legal process, regulatory direction, investigation requirements or natural justice considerations.

Whistleblowers should also keep the matter confidential and avoid discussing the report with unauthorised persons, except where required by law or authorised by Cyclect.

7. Non-Retaliation

Cyclect does not tolerate retaliation against any person who makes a whistleblowing report in good faith or assists in an investigation.

Retaliation includes, but is not limited to:

  1. dismissal, demotion or suspension;
  2. harassment, intimidation or bullying;
  3. discrimination or unfair treatment;
  4. adverse changes to work duties, reporting lines or employment conditions;
  5. threats, coercion or victimisation;
  6. exclusion from work opportunities;
  7. disciplinary action taken because of a good-faith report;
  8. any other conduct intended to punish or disadvantage a whistleblower.

Any person who retaliates against a whistleblower or investigation participant may be subject to disciplinary action, including termination of employment or contract, and may also face legal or regulatory action.

A whistleblower who believes that retaliation has occurred should report the matter immediately to Compliance.

8. Good Faith Reporting

A whistleblower does not need to prove the concern before making a report.

However, the whistleblower must act in good faith and have reasonable grounds to believe that the information provided is true or may be true.

A report made in good faith will not result in disciplinary action merely because the concern is not substantiated after review or investigation.

9. Frivolous, Malicious or False Reports

Cyclect does not tolerate misuse of whistleblowing channels.

A report may be considered improper if it is made:

  1. maliciously;
  2. knowingly false;
  3. without reasonable basis;
  4. for personal gain;
  5. to harass, intimidate or damage another person;
  6. to abuse company processes;
  7. to deliberately mislead Cyclect, Compliance, management, the Board or investigators.

Where an investigation finds that a whistleblower knowingly made a false, frivolous or malicious report, Cyclect may take appropriate action, including disciplinary action, termination of employment or contract, and legal action where appropriate.

10. Investigation Outcomes and Follow-Up Actions

After reviewing or investigating a report, Cyclect may take appropriate action, including:

  1. closing the matter where there is insufficient basis for further action;
  2. issuing guidance, reminders or process improvements;
  3. strengthening internal controls;
  4. recovering losses or assets;
  5. disciplinary action against employees;
  6. termination of contracts or business relationships;
  7. reporting the matter to regulators or law enforcement;
  8. commencing legal proceedings;
  9. other corrective or preventive actions.

Cyclect may provide feedback to the whistleblower where appropriate and practicable. However, Cyclect may not disclose investigation details, disciplinary outcomes or confidential information.

11. Personal Data

Personal data submitted under this Policy may be collected, used, disclosed and retained by Cyclect for purposes including:

  1. receiving and assessing whistleblowing reports;
  2. conducting reviews and investigations;
  3. contacting whistleblowers or witnesses;
  4. escalating matters to Compliance, the Chief Executive Officer or the Board;
  5. taking corrective, disciplinary, legal or regulatory action;
  6. complying with legal, audit, governance and record-keeping requirements;
  7. protecting Cyclect’s rights, personnel, assets, systems and operations.

Cyclect will handle personal data in accordance with applicable Singapore personal data protection requirements and Cyclect’s Privacy Statement.

12. Records and Retention

Cyclect will maintain records of whistleblowing reports, assessments, investigations and outcomes as appropriate.

Such records will be retained for as long as necessary for legal, regulatory, audit, governance, employment, compliance, risk management or business purposes.

Access to whistleblowing records will be restricted to authorised persons on a need-to-know basis.

13. Communication of This Policy

Cyclect will make this Policy available through appropriate channels, which may include:

  1. Cyclect’s corporate website;
  2. employee onboarding materials;
  3. internal policy portals or shared drives;
  4. periodic employee communications;
  5. training or compliance briefings;
  6. supplier, contractor or partner communications where relevant.

Employees are expected to understand and comply with this Policy.

Managers and supervisors are expected to support a culture where genuine concerns can be raised without fear of retaliation.

14. Review and Amendment

Cyclect may review, amend or update this Policy from time to time to reflect changes in law, governance requirements, business operations or internal controls.

Any material amendment should be approved by Compliance, the Chief Executive Officer or the Board of Directors, as appropriate.