Policy and Procedure

  1. Purpose and Scope

MindChamps PreSchool Limited (the “Company”) is committed to a high standard of corporate compliance, ethical behavior and corporate governance. This whistleblowing policy (this “Policy”) is intended to provide an avenue for the Company’s employees, suppliers, customers and other stakeholders to express concerns on any serious wrongdoing, such as unlawful conduct, financial malpractice, fraud, or corruption.

This Policy aims to encourage individuals to be confident in raising their concerns without fear of reprisal, discrimination or adverse consequences. It also allows the investigation of any actual, suspected or anticipated wrongdoing within or by the Company.

Examples of reportable incidents may include, but are not limited to the following:

i.      Forgery, fraud, or any conduct which is an offence by law;
ii.     Breach of legal obligation (eg. breach of contract);
iii.    Serious conflict of interest without disclosure;
iv.    Company’s funds being used in an unauthorised manner;
v.     Intentional provision of incorrect information to public bodies;
vi.    Dangerous or unsafe work environment;
vii.   Sexual or physical abuse; and
viii.  Concealing information about any malpractice or misconduct.

  1. Safeguards

All reports must be made in good faith. An individual raising concerns or providing information about an actual, suspected, or anticipated wrongdoing shall be protected against any reprisal such as employment termination, retribution, or harassment. This policy is however not intended to be used for taking up personal grievances, or where there are other more suitable channels available. Any false, misleading and frivolous claims will be disregarded.

  1. Reporting Procedure and the Handling of Reports

Concerns may be raised in writing to the Audit Committee Chairman through [email protected].

All concerns raised will be independently reviewed by the Audit Committee and all information provided will be kept strictly confidential, except as necessary and appropriate to conduct any relevant investigation(s).

Reports should be made as soon as practicable, and include, in as much detail as possible, the identity and particulars of the parties involved, background, history of events and any other relevant information or documentation that would assist in investigations. Concerns or information provided anonymously will be given due consideration by the Company. However, an individual is encouraged to identify himself or herself and provide relevant contact details, in case further clarification or information is required.

Where appropriate, the Audit Committee may lead the investigation, or consult with the CEO and/or senior management and direct the complaint to the best department or persons to address the concern. The Company reserves the right to refer any concerns or complaints to the relevant external authorities and/or take any appropriate internal disciplinary actions or measures.