WHISTLE-BLOWING POLICY

Metro Holdings Limited and its subsidiaries (’the Group’) are committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements and any legislation relating thereto. In line with this commitment, the Whistle-blowing Policy (‘Policy’) aims to provide an avenue for employees and outside parties to raise concerns and offer reassurance that they will be protected from reprisals or victimisation for Whistle-blowing in good faith.

This Policy applies to all employees of the Group and outside parties such as suppliers, customers, contractors and other stakeholders.

Employees and outside parties may use the procedures set out in the Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, insider trading, collusion with competitors, serious breaches of Group policy, unsafe work practices or any other matters involving fraud, corruption and employee misconduct.

Any person who raises a genuine concern under this Policy will not be at risk of losing his or her job or suffering from retribution or harassment as a result. Provided that the person who whistle-blows is acting in good faith, it does not matter if he or she is mistaken.

However, the Group does not condone frivolous, mischievous or malicious allegations. Any person(s) making such allegations will face disciplinary action as the Audit Committee deems appropriate.

The Group encourages the whistle-blower 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 whistle-blower could or would not be treated with strictest confidentiality include:

• Where the Group is under a legal obligation to disclose information provided
• 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, we will endeavour to discuss this with the whistle-blower first.

The complaint should include details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible, and contact details, in case further clarification is required. You may forward your concerns either in writing or via the online form below:

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 Audit Committee
• The External or Internal Auditor
• Forensic Professionals
• The Police or Commercial Affairs Department

The amount of contact between the whistle-blower 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 whistle-blower during the course of the investigation.

The investigating officer(s) will communicate the findings of the investigation(s) to the Audit Committee for their necessary action.