Whistle Blowing Policy

Objectives:

• To provide proper avenues for employees and other stakeholders to report improper, unethical, or inappropriate behaviour.
• To assure all parties that reports will be properly addressed, treated with confidentiality, and supported by adequate safeguards to protect whistleblowers from reprisal in any form.
• To promote and reinforce a culture of accountability, integrity, and transparency across the Company.
• Employees’ grievances (if any) would be addressed via human resource procedures and not covered under this policy.

Actual and suspected wrongdoings within the Group can be reported and include, but not limited to, the following:

• Misconduct relating to financial reporting, accounting or other financial matters
• Corruption, bribery and other unlawful activities
• Unethical conduct or abuse of power and authority
• Health and safety risks
• Damage to the environment
• Concealment of any of the above

• The Audit and Risk Committee (ARC) of the Company has been designated as the independent function responsible for oversight and maintaining of whistleblowing, as well as investigating reported concerns.
• A whistleblower can report his/her concern directly to the ARC via email: whistle@theassemblyplace.com.

• Employees or other stakeholders who become aware of suspected fraud, unethical behaviour, or policy violations are encouraged to report their concerns promptly through email with full details on the event and reasons for concern.
• To ensure an effective investigation, reports should include:

• A clear description of the misconduct or issue.
• Names of individuals involved (if known).
• Dates, locations, and relevant documentation (if applicable).
• Any evidence supporting the claim.

Concerns conveyed anonymously are difficult to verify and may hinder investigation. The whistleblower is strongly encouraged to provide his/her name and contact details in case he/she needs to be contacted for more information.

• All reports of incidents, including information or evidence provided, will be handled with strictest confidentially, unless the Group is under legal obligation to disclose information.
• The identity of whistleblower shall be kept confidential so long as it does not obstruct or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

• The Company prohibits harassment or victimisation of any kind against a whistleblower who submits a report,
• No one should suffer reprisal as a result of reporting a genuine concern, even if they turn out to be mistake,
• While this policy is meant to protect the whistleblower from any unfair treatment as a result of their report, the Company does not condone any frivolous or malicious allegations. If investigations reveal that the whistleblowing report was done so maliciously for the whistleblower’s personal gain, appropriate action may be taken in accordance with the law.

The ARC shall review this policy annually. Revision (if any) shall be approved by the Board.

This policy shall be published on the Company’s website.