Introduction

As part of our Risk Management Framework, the Manager of Sabana REIT, has put in place a whistleblowing channel to help external stakeholders report, without fear of retaliation, discrimination or adverse consequences, on any wrongdoing that they may observe on the part of its officers and directors in their course of work, in particular, with respect to their obligations to the interests of the Trust.

Who should report?

• Tenants
• Vendors

What to report?

Any wrongdoings involving:

1. fraudulent activities;
2. illegal activities;
3. bribery and corruption;
4. conflict of interest and abuse of position for personal gain;
5. insider trading;
6. gross misuse or misappropriation of Trust’s assets; and
7. any acts or omissions which are deemed to be against the interests of the Trust, the laws, regulations or public policies.

How to report?

Wrongdoings should be reported in writing, using the format set out in Appendix A, and emailing it to whistle-blowing@sabana.com.sg.

How we will act

All whistleblowing reports will be directed to the Chairman of the Audit Committee.

All information provided will be investigated, but consideration will be given to these factors:

1. severity of the issue raised;
2. credibility of the concern or information; and
3. likelihood of confirming the concern or information from other sources.

Depending on the nature of the concern raised or information provided, the investigation may be conducted involving one or more of these persons or entities:

1. The Audit Committee;
2. The Investigating Committee;
3. The External or Internal Auditor;
4. Forensic Professionals or Private Investigators; and
5. The Police or Commercial Affairs Department.

If, at the conclusion of an investigation, it is determined that a violation has occurred or the allegations are substantiated, remedial action commensurate with the severity of the offence will be taken.

Regardless of the significance of allegations or the outcome, all whistleblowing reports will be tabled and discussed at Audit Committee meetings.

How we will respond

Usually, within four weeks of receiving a whistleblowing report, the Chairman of the Audit Committee will write to the whistleblower:

1. acknowledging that the concern has been received;
2. indicating how it propose to deal with the matter;
3. giving an estimate of time it will take to provide a full response;
4. informing whether any initial enquiries have been made;
5. supplying information on support available to the whistleblower; and
6. informing the whistleblower if further investigations will take place and if not, to provide reasons.

Issues to consider

It is essential for the Audit Committee to be given all critical information in order to be able to effectively investigate any wrongdoing. As such, the report should provide as much detail and be as specific as possible. It should contain details of the parties involved, dates or period of time, the type of wrongdoing, evidence substantiating the wrongdoing, and contact details.

Incomplete &/or anonymous reports are unlikely to be acted upon, as it is extremely difficult and often impossible to investigate if insufficient information is provided and the Audit Committee has no means to contact the whistle-blower to seek further information or gather additional facts, diminishing the likelihood of confirming the purported allegations.

Acting in good faith

All whistle-blowers are expected to:

1. act in good faith;
2. have reasonable grounds; and
3. not making the report for personal gain.

Acting in good faith means without malicious intentions and in the better interest of the Trust. If allegations are proven to be malicious, appropriate actions, including legal action and blacklisting, may be taken.

Confidentiality

The identity of the whistle-blowers will be kept confidential. However, their consent will be sought should there be a need to disclose their identity for investigation purposes. Please note the investigation may be impacted if they do not provide their consent.

Exceptional circumstances under which information provided by the whistle-blower could or would not be treated with strictest confidentiality include:

1. where there is a legal obligation to disclose information provided;
2. where the information is already in the public domain;
3. where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; and
4. where the information is given to the Police or other authorities for criminal investigation.

In the event the Audit Committee is faced with a circumstance not covered by the above, and where the whistle-blower’s identity is to be revealed, it will endeavor to discuss this with the whistleblower first.

Protection from Retaliation

The Audit Committee shall ensure that the whistle-blower is not victimised in any way, even if it becomes necessary for him/her to come forward to give evidence. Any employee, officer or director that retaliates against the whistle-blower who has filed a report in good faith may be subject to appropriate action, including legal action, where applicable.

The Manager reserves the right to modify the contents to maintain compliance with the applicable laws and regulations or accommodate organisational changes.

Appendix A: Download Whistle Blowing Form (here)