Whistle-Blowing Policy

At Gaylin, we are committed to maintaining a high standard of corporate governance.

Good corporate governance is an integral element of a sound corporation and enables a company to be more transparent and forward-looking, and also acts as an effective safeguard against fraud and dubious financial engineering. With this in mind, we expect honesty, integrity and accountability at every level of the Company. The Board and the Management believe that an effective whistle-blowing arrangement will act as a deterrent to malpractice and wrongdoing, encourage openness, promote transparency, underpin our risk management systems and enhance business practice thereby increasing the reputation of Gaylin and its management.


The purpose of this whistle-blowing policy is to put in place an arrangement providing guidance on suspicion, reporting and investigation of fraudulent practices within Gaylin and its subsidiary/associated companies (collectively the "Group").


The objectives of the policy are:

  • To maintain a high standard of corporate governance
  • To provide a channel of communication to the employees of the Group to report fraudulent practices and to guide employees on actions to address their concerns on suspicions fraudulent activities
  • To provide a process in investigations and management reporting

Scope of Policy

This policy deals with concerns on improprieties and wrongdoings:

  • Affecting the financial position of the Company;
  • Relating to the honesty and integrity of the Company's dealings;
  • Relating to the honesty and integrity of any employee or director in the course of his or her employment or dealings with or on behalf of the Company, including:
    • Conflicts of interest: An employee or officer should always act in the best interest of the Company. A "conflict of interest" occurs when an individual's personal interests interferes or appears to interfere with the interests of the Company.
    • Taking Advantage of Corporate opportunities: Employees and directors are prohibited from taking advantage of corporate property, information, or position, or opportunities arising from these, for personal gain or to compete with the Company.
    • Confidentiality: Employees and directors must maintain the confidentiality of information entrusted to them by the Company or its customers, except when disclosure is authorised or legally mandated.
    • Fair dealing: Each employee and director should endeavor to deal fairly with the Company's customers, suppliers, competitors and employees. None should take unfair advantage of anyone through dishonesty, misrepresentation of material facts or any other unfair practice.
    • Protection and proper use of company assets: All employees and officers should protect the Company's assets and ensure their efficient use for legitimate business purposes.
    • Compliance with laws, rules and regulations (including insider trading laws): We actively promote compliance with laws, rules and regulations, including insider trading laws. Insider trading is both unethical and illegal.
    • Unethical behavior: We actively promote ethical behavior and encourage employees to report any misconduct in this regard.

What is not covered by this policy

Employees should not use the avenues provided by this policy to deal with any matters thatare covered by other procedures even if serious or sensitive such as:

  • Complaints about the terms or other aspects of your employment
  • Customers' complaints about our products and services

This policy applies to any of the above actions involving employees, vendors/contractors, consultants, and/or any other parties whom the Group has a business relationship with. Employees of the Group are responsible to highlight any suspicion of fraudulent practices and inappropriate activities within the Group and bring them immediately to the attention of the Chairman of Audit Committee:

Mr Lim Shook Kong