ICHAM

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Whistleblowing Policy

At ICHAM Pte. Ltd. (“Company”), we are committed to conducting our business with the highest standards of integrity, accountability and transparency. The Company maintains a Whistleblowing Policy to provide a secure and confidential channel for reporting concerns relating to misconduct, breaches of law, unethical behaviour or regulatory non-compliance.

What Can Be Reported

Whistleblowing reports may cover, but are not limited to:

• Financial fraud, theft, misappropriation, or falsification of records;
• Bribery, corruption, or abuse of authority;
• Breaches of the Securities and Futures Act (“SFA”), Financial Advisers Act (“FAA”), or MAS guidelines;
• Money laundering or terrorism financing activities;
• Workplace misconduct including harassment, discrimination or unfair employment practices; or
• Conflicts of interest or other unethical behaviour.

Protection of Whistleblowers

The Company ensures that:

• Reports made in good faith will be treated seriously, investigated impartially, and handled with confidentiality;
• The identity of whistleblowers will be protected, unless disclosure is required by law or regulatory authorities; and
• Whistleblowers will not face retaliation, harassment or adverse treatment for raising genuine concerns.

Reporting Channels

Concerns may be raised through the following secure channels:

• Dedicated Email: whistleblowing@icham.sg
• Secure Online Form: https://forms.office.com/r/NwFi29SkmP
• Written Submission: Addressed and marked “Private and Confidential” to the Whistleblowing Committee only; or
• In Person: Directly to any member of the Whistleblowing Committee (CEO, Head of Compliance, or Head of Human Resources)

The Whistleblowing Committee (comprising the CEO, Head of Compliance and Head of Human Resources) is responsible for receiving, assessing and investigating reports. Serious or sensitive matters may be escalated to the Board of Directors and, where necessary, to MAS or other regulatory or law enforcement agencies.

Confidentiality and Handling of Reports

All reports will be handled with the strictest confidentiality. Access is limited to authorised members of the Whistleblowing Committee. Information and supporting documents will be securely stored and only shared where necessary for the purposes of investigation and resolution.

Commitment to Integrity

This Whistleblowing Policy reflects the Company’s zero-tolerance stance towards misconduct and its commitment to fostering a culture of openness, accountability and compliance in line with MAS regulatory expectations.