CORPORATE GOVERNANCE Grievance Handling and Whistle-Blowing Policy A whistle-blowing policy has been put in place by the Managers which sets out the procedures for the Managers’ employees and parties who have dealings with the Managers, including vendors and customers, to make a report on misconduct or wrongdoings relating to the Managers and their officers. Reportable suspected wrongdoings include but are not limited to misconduct relating to financial matters, corruption, failure to comply with legal or regulatory obligations, significant breaches of policies or internal controls and endangerment of the health and safety of an individual. Procedures are put in place to provide such employees and parties with independent, well defined, accessible and trusted channels to report suspected fraud, corruption, dishonest practices or other improprieties in the workplace, and for the independent investigation of any reported incidents and appropriate follow up action. The Managers ensure that the identity of the whistle-blower is kept confidential. Anonymous reporting is allowed. However, concerns expressed anonymously are difficult to act upon and whistle-blowers are encouraged to provide their contact information so that clarifications can be sought during investigations. The objective of this policy is to encourage the reporting of such matters so that employees or external parties making any reports in good faith will be able to do so with the confidence that they will be treated fairly and, to the extent possible, be protected from reprisal. The Managers are committed to ensuring protection of the whistle-blower against detrimental or unfair treatment. The ARC maintains oversight and monitoring of whistle-blowing reports made in good faith at its scheduled meetings. Independent, thorough investigation and appropriate follow up actions are taken. The outcome of each investigation is reported to the ARC. All employees of the Managers are informed of this policy which is made available on CLI Group’s intranet and at https://www.capitaland.com/en/more-from-capitaland/whisteblowing-policy.html. Business Continuity Management The Managers have implemented a Business Continuity Management (BCM) programme that puts in place the prevention, detection, response and, business recovery and resumption measures to minimise the impact of adverse business interruptions or unforeseen events on the Stapled Group’s operations and also has in place a Business Continuity Plan (BCP). Under the BCP, Management has identified the critical business functions, processes and resources, and is able to tap on a pool of CLI Group’s employees who are trained under a Business Psychological Resilience Programme to provide peer support to colleagues following the occurrence of adverse events. As part of the BCP, periodic desktop exercises and drills, simulating different scenarios, are carried out to stress-test the effectiveness of processes, procedures and escalation protocols. This holistic approach under the BCP serves to ensure organisational and staff preparedness and readiness to deal with adverse business disruptions such as acts of terrorism, cyber attacks, data breaches and epidemics. This approach aims to minimise financial loss to CLAS, allowing the Managers to continue to function as the managers of CLAS and mitigate any negative effects that the disruptions could have on the Managers’ reputation, operations and ability to remain in compliance with relevant laws and regulations. The Managers have also acquired insurance policies for the Stapled Group on business interruption events. Anti-Money Laundering and Countering the Financing of Terrorism Measures As a holder of a Capital Markets Services Licence issued by MAS, the REIT Manager abides by the MAS’ guidelines on the prevention of money laundering and countering the financing of terrorism. Under these guidelines, the main obligations of the REIT Manager are: (a) evaluation of risk; (b) customer due diligence; (c) suspicious transaction reporting; (d) record keeping; (e) employee and CMSL Representative screening; and (f) training. 132 CAPITALAND ASCOTT TRUST
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