Whistle-Blowing Policy

Approved by: Board of Directors
Effective Date: 1 May 2026
Last Reviewed: 30 April 2026

 Policy Statement

KTC Board is committed to strengthen and maintaining the standards of integrity, transparency and accountability in the conduct of its business. This Whistle‑Blowing Policy provides a safe and independent channel for employees and relevant stakeholders to raise concerns, in good faith about suspected misconduct or improper practices involving the Group.

The Group encourages the reporting of such concerns and is committed to addressing them promptly, fairly and responsibly.

 Purpose

The purpose of this policy is to:

  • Encourage the reporting of genuine concerns relating to improper conduct, illegal acts or unethical behaviour
  • Ensure that disclosures are handled independently, objectively and confidentially
  • Protect whistle‑blowers from retaliation when concerns are raised in good faith
  • Support the Board in fulfilling its oversight responsibilities in line with good corporate governance practices

 Scope of Reportable Concerns

Concerns that may be reported under this policy include, but are not limited to, the following:

  • Forgery or falsification of records
  • Fraud, theft, or misappropriation of funds or assets
  • Breaches of laws, regulations, or internal policies
  • Abuse of authority or misrepresentation of power
  • Corruption, bribery, or facilitation payments
  • Harassment or inappropriate workplace behaviour
  • Discrimination based on gender, race, disability, or other protected characteristics
  • Any other misconduct as defined under the Group’s Disciplinary Policy and Code of Conduct

 Reporting Channel

To ensure independence and objectivity, all whistle‑blowing reports should be submitted directly to the Group’s appointed Internal Auditor, who reports to the Board:

Mr Willy Leow
BDO LLP – Internal Auditor
Email: willyleow@bdo.com.sg
Telephone: +65 6828 9118

All reports received will be assessed and, where appropriate, escalated to the Board for review and further action.

 Confidentiality and Protection

Whistle‑blowers are required to identify themselves when making a report to facilitate proper investigation. The Group is committed to protecting the identity of whistle‑blowers and will treat all disclosures with the strictest confidentiality.

Information will only be disclosed on a need‑to‑know basis or where required by law or regulatory authorities.

The Group strictly prohibits any form of retaliation, harassment, or adverse action against individuals who report concerns in good faith.

 Oversight and Governance

The Board has overall responsibility for the oversight of the Whistle‑Blowing Policy and ensures that appropriate actions are taken in response to substantiated reports.

The policy is reviewed periodically to ensure continued relevance and alignment with regulatory and governance best practices.