Whistleblowing Policy

Channel for reporting

If you are aware of wrongful practices or improprieties involving or affecting Nam Lee Pressed Metal Industries Limited or any of its subsidiaries (“Nam Lee”), you can report this to the email address whistleblowing@namlee.com.sg.

Wrongful practices or improprieties

Wrongful practices or improprieties refer to any activity or omission by an employee of Nam Lee, which is an inappropriate business conduct or represents unethical behaviour.

It may concern questionable operational or trade practices, financial or financial reporting matters, workplace harassment such as intimidating or obstructive behaviour; or failure to observe regulatory obligations.

Employees of Nam Lee are expected to raise human resource (“HR”) matters through existing internal HR channels, unless the matter involves HR management itself.

Handling of reports

The recipients of the emails to whistleblowing@namlee.com.sg are independent directors of Nam Lee Pressed Metal Industries Limited.

The whistleblowing policy provides a channel for individuals to report genuine misconduct or wrongdoing without fear of reprisal. It provides a framework for independent investigations and follow through on reports.

There shall be no discrimination, retaliation or harassment of any kind against a whistle-blower who submits a complaint or report in good faith and without malice through the above channel.

The identity of the whistle-blower will be protected and kept in confidence. However, under certain circumstances, the identity of the whistle-blower may be revealed to parties on a need-to-know basis such as the law enforcement agencies.

The confidentiality provisions do not apply if :

1. it is determined that the Complaint was lodged with malicious or mischievous intent, has been publicised and is potentially harmful to the orderly conduct of business and the reputation of the Group; or
2. the identity of the complainant is already public knowledge such as through the use of social media by the complainant.

You may choose to raise your concerns anonymously. However, concerns expressed anonymously may lack credibility and may hinder follow-up clarifications and investigations. We therefore highly encourage whistle-blowers to identify themselves to facilitate the investigation process.

Information in the report

In making a report, the following information should be provided to the extent known or applicable. You are encouraged to attach relevant documents to facilitate investigations.

• Name of person/department involved;
• Description of the incident, including where, when and how did the incident occur;
• Details of any witnesses and evidence;
• Value of any money or assets involved;
• Any other information that may substantiate the concern; and
• Name of whistle-blower or ways to contact for any further investigation.