Whistleblowing Policy

SBS TRANSIT LTD

OUR COMMITMENT 
WHISTLEBLOWING POLICY

This Policy applies to SBST Transit Ltd and its subsidiaries (“SBST”).

(i)    What is Whistleblowing? 

As employees are expected to abide by the principles of the SBST Code of Business Conduct (“Code”) and also maintain and demonstrate the highest professional standards and ethical conduct in the performance of their duties, they are encouraged to bring to the attention of Management any violations of the Code; and/or any unethical or unlawful business conduct or dealings, with the intention for necessary corrective actions to be taken to address the violations.

(ii)    Who is a Whistleblower? 

A whistleblower may be an employee or external party who, in the course of his/her duties or personal engagement with the Company or employee has witnessed or who has knowledge that another fellow employee has previously engaged, is currently engaging or will be engaging in practices/activities that will be in violation of the Code, or unethical or unlawful business conduct or dealings, and decides to highlight these practices/activities/conduct/dealings to Management with a view that necessary corrective actions will be taken to prevent the occurrence of such undesired practices/activities/conduct/dealings.

Whistleblowing is not a means by which anyone including a disgruntled employee can abuse, wreak revenge on or sabotage another person or fellow employee without any just cause or to hold an employee at ransom. Any act of whistleblowing must be genuine, substantiated with proper evidence, and directed to the SBST Alert Line within a reasonable time. Where necessary, the whistleblower must be prepared to testify or provide a statement in respect of the contents of his/her report. Whistleblowing reports should not be based on unfounded or malicious allegations made against another employee. SBST will not tolerate any abuse of its whistleblowing process.

A whistleblower does not have to be directly or indirectly affected by or have a personal interest in the outcome of the actions giving rise to the whistleblowing. So long as an employee has a genuine concern and reasonable grounds to believe that the actions of a fellow employee is in breach or will be in breach of the Code or principles of ethical conduct and fair dealing, he can be a whistleblower. However, the whistleblower must act in good faith at all times.

This Policy allows for reporting by employees or external parties of such matters, without fear of reprisal, discrimination or adverse consequences, and also permits SBST to address such reports by taking appropriate action, including, but not limited to, disciplinary action or terminating the employment and/or services of those responsible.

(iii)     Activities Giving Rise to Whistleblowing 

Listed below are some activities that could potentially give rise to whistleblowing. It is not an exhaustive list:

  • Theft, damage or misappropriation of company’s properties, using company’s properties for own benefit or any unlawful purpose, or unlawful dissemination or disclosure of company’s proprietary information, know-how or trade secrets;
     
  • Fraud. For example
    1. falsification or alteration of SBST’s records, accounts or financial information;
    2. submission of false invoices and claims for reimbursement of expenses;
    3. failure to account for or misuse of company’s monies in possession; and
    4. knowingly providing information which is false or misleading;
  • Engaging in activities prohibited by law; or activities in breach of any legal or contractual obligations. For example, failure to perform any material terms of any contract without any lawful reason; 
     
  • Unlawful or unethical conduct. For example, violence, threatened violence, bullying, bribery or acceptance of monies, gifts or monetary benefits in exchange for personal favours;
     
  • Making statements or remarks which are defamatory or cause disruption to racial harmony;
     
  • Sexual harassment or adopting discriminatory practices;
     
  • Trading in the securities of SBST or any other listed company within the ComfortDelGro Group (ComfortDelGro Corporation Limited and its subsidiaries) on a short-term consideration and/or while in possession of unpublished material price-sensitive information related to those securities, including the procuring or providing of such information to any third party to deal in such securities;
     
  • Misuse, including the downloading and sending of information which will infringe third party’s copyright or; information that is derogatory or offensive to a third party;
     
  • Engaging in activities or practices that will pose a danger to the health and safety of others or the environment;
     
  • Conflict of interest without disclosure. For example, a superior and his/her direct reporting subordinate are in a relationship; and
     
  • Breach of SBST’s policies or the Code.

(iv)    SBST Alert Line 

The SBST Alert Line comprising the following personnel has been set up to facilitate the reporting of incidents and the handling of information or evidence on matters that will give rise to whistleblowing:

  • Group Chief Internal Audit Officer (“GCIAO”):
    DID: +65 6383 7010
    Email address: gciao@comfortdelgro.com

    Mailing address:
    205 Braddell Road, Singapore 579701,
    East Wing Level 7, GCIAO Office

    Alternatively, the complainant may submit his/her concerns via the intranet https://wkflwsvr/SBSTIntranet/WhistleBlowing.asp

  • Any complaints involving the GCIAO may be reported to the Chairman of the Audit & Risk Committee (“ARC”) via this email: ARC_Chairman@sbstransit.com.sg
  • The submission of complete information is important and helps in investigations. Please provide the following, where possible:
    1. Name(s) of person(s)/company(ies) involved
    2. Date, time and location of incident
    3. Frequency of occurrence of the incident
    4. Value of any money or assets involved
    5. Physical evidence
    6. Details of incident
    7. Any other information that may substantiate the feedback/complaint

(v)    Investigations and Disciplinary Actions

The ARC is responsible for the independent oversight and monitoring of whistleblowing, including the investigations conducted by Group Internal Audit.

All reports of incidents, including information and evidence provided, on matters relating to whistleblowing will be handled discreetly and every effort will be made to maintain confidentiality of the information provided, within the limits of the law. Whistleblowing in letters or other sources like those received by the Corporate Communications / Human Resource departments will also be circulated to the GCIAO.

Reported incidents will be dealt with promptly and thoroughly. GCIAO will administer and assess the cases, other than incidents involving GCIAO. For significant cases, GCIAO will propose to the ARC Chairman to proceed for investigation.

Group Internal Audit will lead the investigation and work with SBST’s Human Resource department or the Business Unit to which the case relates. The outcome of the investigation will be formally reported to the Management and the ARC.

After consultation with relevant senior management of SBST, appropriate and fair disciplinary action, including dismissal, may be meted out against those who are found guilty. In instances where the relevant laws have been infringed, SBST will report such infringement to the relevant regulatory authorities. Where appropriate, internal control measures and procedures will be improved upon or additional measures put in place to prevent the recurrence of such incidents.

The number of whistleblowing cases that proceed for investigation will be tracked and recorded by GCIAO, and will be updated to the ARC quarterly.

To ensure that employees who whistleblow are not victimised, black-listed or discriminated by his/her supervisors or fellow colleagues, SBST will not reveal the employees’ identities or information leading to their identities being known. SBST views such victimisation, black-listing or discrimination seriously and will not hesitate to take disciplinary action against those who are involved in such practices.

All employees are responsible to ensure the highest standards of ethics, honesty, openness and accountability in line with SBST’s commitment to enhance good governance, transparency and safeguard the integrity of SBST. Training is provided regularly to remind staff to adhere to this Policy.

SBST will periodically review this Policy to ensure its continued effectiveness.