CLEARTRADE EXCHANGE PTE LTD

Whistle-blowing Policy
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 2 of 10

Whistle-blowing Policy

Cleartrade Exchange (CLTX) whistle blowing policy is part of our internal controls to ensure 

that there is an avenue for employees and external parties to raise concerns, and at the same time, 

be assured that they will be protected from reprisals or victimization.

The Policy is intended to encourage employees to raise concerns, in confidence, about possible 

irregularities.

Policy objective:

- Provision of proper avenues by which employees or any individual may, in confidence and 

without fear of reprisal, swiftly raise concerns about possible improprieties, irregularities, 

malpractice, suspected breach or fraud, or activity, transactions or behavior that may not 

accord with the law and/or the firm’s policies/procedures to the attention of Management and 

Compliance Department, and receive feedback on any action taken.

- Give whistle-blowers the assurance that they will be protected from reprisals or victimization 

for whistle-blowing in good faith.

- Good check and balance for the Company as a whole.

- To instill an internal culture of integrity.

- Deter wrongdoing and to promote standards of good corporate practices.

- Ensure that arrangements are in place for the independent receipt of whistle-blowing reports 

and investigation of such matters, and for appropriate follow up action.

Protection for whistle-blowers

- If an employee raises a genuine concern under this Policy, he or she will not be at risk of 

losing his or her job or suffering from retribution or harassment as a result. Provided that the 

employee is acting in good faith, it does not matter if he or she is mistaken.

- Where the identity of the good faith whistle-blower is known, steps should be taken to ensure 

that the staff is not subjected to reprisals.

- However, the Company does not condone frivolous, mischievous or malicious allegations. 

Confidentiality of whistle-blowers

- The Company encourages the whistleblower to identify himself/herself when raising a 

concern or providing information. All concerns will be treated with strict confidentiality.

- Exceptional circumstances under which information provided by the whistleblower could or 

would not be treated with strictest confidentiality include:

 Where the Company is under a legal obligation to disclose information provided

 Where the information is already in the public domain

 Where the information is given on a strictly confidential basis to legal or auditing 

professionals for the purpose of obtaining professional advice

 Where the information is given to the Police or other authorities for criminal 

investigation

- In the event we are faced with a circumstance not covered by the above, and where the 

whistle-blower’s identity is to be revealed, the Company will endeavor to discuss this with 

the whistle-blower first.
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 3 of 10

Disadvantages of providing information anonymously

- Concerns expressed anonymously can be much less persuasive and may hinder investigation 

work as it is more difficult to look into the matter or to protect the whistleblower’s position.

- Accordingly, the Company will consider anonymous reports, but concerns expressed or 

information provided anonymously will be investigated on the basis of their merits.

Scope of the Policy

- Unethical and improper practices or alleged wrongful conduct

- Non-compliances with regulatory requirements or corporate policies

- Questionable or suspicious practices 

- Any other acts that may have a regulatory, business and/or financial impact

- Some examples of concerns covered by this Policy include (this list is not exhaustive):

 Concerns about the Exchange’s accounting, internal controls or auditing matters

 Breach of or failure to implement or comply with the Exchange’s policies or code of 

conduct

 Impropriety, corruption, acts of fraud, theft and/misuse of the Exchange’s properties, 

assets or resources

 Conduct which is an offence or breach of law

 Abuse of power or authority

 Serious conflict of interest without disclosure

 Intentional provision of incorrect information to public bodies

 Any other serious improper matters which may cause financial or non-financial loss to 

the Exchange, or damage to the Exchange’s reputation

 Fraud against investors, or the making of fraudulent statements to the Singapore 

Exchange Securities Trading Limited, members of the investing public and regulatory 

authorities

 Acts to mislead, deceive, manipulate, coerce or fraudulently influence any internal or 

external accountant or auditor in connection with the preparation, examination, audit or 

review of any financial statements or records of the Exchange

 Concealing information about any malpractice or misconduct

The above list is intended to give an indication of the kind of conduct which might be 

considered as negative activities which would adversely affect the company as a whole. In 

cases of doubt, the whistleblower should seek to speak to his or her immediate superior or 

follow the procedure for reporting under this Policy
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 4 of 10

Who to whistle-blow to

- The recipient of the whistle-blowing report should be independent and not subject to undue 

influence or pressure by Management.

- These personnel could be considered as appropriate independent recipients if not 

directly/indirectly incriminated by matters in the report:

 Compliance

 Senior Management

 Head of Department

- Recipients of whistle-blowing reports are responsible for ensuring that all feedback received 

are accounted for, appropriately secured (with restricted user access) and reported to the 

Compliance Department and Senior Management.

- Compliance Department may appoint a person totally unassociated with the matter to look 

into it. 

Whistle-blowing channels

- Concerns or information are preferably raised or provided in writing (letter, e-mail or using 

the Whistle-blowing Form attached at the end of this document).

- It is recommended that the whistle-blower sets out in details the background and history of 

events and the reasons for the concern.

- If the whistleblower is not comfortable about writing in, he or she can telephone or meet the 

appropriate officer in confidence at a time and location to be determined together.

Important notes when whistle-blowing

- The earlier the concern is raised the easier it is for the Company to take action.

- The Company expects the whistleblower to provide his/her concern in good faith and to 

demonstrate to the appropriate officer that there are sufficient grounds for his/her concern.

- The Company also recognizes that the whistleblower may wish to seek advice and be 

represented by his/her legal counsel.

- Employee(s) is/are to treat whistle-blown information with strictly confidentiality and any 

employee found to be leaking such information to other staff within the Company (other than 

those involved in the investigation) and/or to anyone outside the Company will face 

disciplinary action in accordance with the Company’s Disciplinary Procedures.
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 5 of 10

How the Group handles whistle-blowing reports

- The Group assures you that any concern raised or information provided will be investigated, 

but consideration will be given to these factors:

 Severity of the issue raised

 Credibility of the concern or information

 Likelihood of confirming the concern or information from attributable 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:

 The Compliance Department

 The External Auditor

 Forensic Professionals

 The Police or Commercial Affairs Department

- Adequate procedures to track the actions taken in relation to concerns raised and to ensure 

appropriate and timely follow-up action will be taken to investigate and, if necessary, resolve 

problems indicated by whistle-blowing.

- Notwithstanding that the report is anonymous, the investigating team will evaluate the 

information provided, on the basis of credibility and materiality having regard to the 

supporting evidence, and distinguishing a bona fide whistle-blowing concern from a 

grievance.

- The amount of contact between the whistleblower and the person(s) investigating the concern 

raised and information provided will be determined by the nature and clarity of the matter 

reported. Further information provided may be sought from the whistleblower during the 

course of the investigation.

- The investigating officer(s) will communicate the findings of the investigation(s) to the 

Senior Management for their necessary action.

- It is a disciplinary matter both to victimize a bona fide whistle-blower and for someone to 

maliciously make a false allegation.

Timeframe for investigation and resolution

- Investigating team is to ensure timely investigation and resolution of matters arising from the 

whistle-blowing reports working around a general timeframe of 2-4 weeks for resolutions, 

depending on the complexity and severity of the case.
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 6 of 10

Cleartrade Exchange Pte. Ltd.

Whistle-blowing Form

I declare that this report and all information I provide herewith are 

reported in good faith.

Do you want to reveal your identity? Yes / No 

If you wish to report anonymously, please be aware that we will not be able to contact you to 

obtain further information and investigation may not be started and completed. Therefore, please 

give us all the details necessary to initiate an investigation or an email address to allow us to 

contact you without being able to identify you. 

Report Filer’s details:-

Name (in full): _____________________________________________________

NRIC/Passport No.: _________________________________________________

Contact details- Email address: _______________________________________

- Mobile phone no.: _______________________________________

- Other contact info.: _____________________________________

Details of person/ department on whom this report is filed:-

Name (in full): _____________________________________________________

NRIC/Passport No.: _________________________________________________

Contact details- Email address: _______________________________________

- Mobile phone no.: _______________________________________

- Other contact info.: _____________________________________

Nature of relationship with filer: _______________________________________
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 7 of 10

Nature of this report

Criminal offence and/or other breach(es) of laws

Breach(es) of internal policy/code of conduct

Concerns about the Group’s accounting, internal controls or auditing matters

Unethical and improper practice(s) or alleged wrongful conduct

Questionable or suspicious practice(s)

Fraud

Corruption

Theft and/misuse of the Group’s properties, assets or resources

Impropriety

Abuse of power or authority

Conflicts of interests without disclosure

Acts to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external 

accountant or auditor in connection with the preparation, examination, audit or review of any

financial statements or records of the Group

Intentional provision of incorrect information and/or fraudulent statements to public bodies, 

investing public and/or regulatory authorities

Concealing information about any malpractice or misconduct

Any other serious improper matters which may cause financial or non-financial loss to the 

Group, 

including damage to the Group’s reputation

Other, please specify: _______________________________________________________
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 8 of 10

Whistle-Blower’s concerns

Detailed description of the incident(s) or occurrences (please attach any supporting 

evidence):

Date/time/frequency of incident(s) or usual occurrences:

Detailed descriptions:

List of evidence if any (please attach if possible):
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 9 of 10
CLTX Whistle-Blowing Policy 

Whistle-blowing Policy Page 10 of 10

Document History

Version Date Summary of Changes Author

1.00 30/03/2015 First draft for Version 1.00 Poh Leong Lim