Ethics, Anti-Corruption & Whistle-Blowing Policy

1. Purpose

MTQ is committed to conducting its business with honesty, integrity and in compliance with all applicable laws and regulations. The company has a zero-tolerance policy towards any form of bribery or corruption and expects all its employees, suppliers, contractors and business partners to uphold the same standards.

This policy outlines the Group's commitment to upholding the highest standards of integrity, ethical conduct, and transparency. We are dedicated to preventing all forms of corruption and bribery in our operations.

2. Scope

This policy applies to all employees, directors, officers, business partners, suppliers, and third parties acting on behalf of the Group.

3. Prohibited Conduct

The following is a non-exhaustive list of examples of improper and unethical activities which the Group prohibits.

Corruption or Bribery: The Group and its employees must avoid any form of offering, giving, receiving, or soliciting bribes to influence decisions. Employees should refrain from giving or accepting gifts, hospitality, or gratuities that could impact decision-making. While small customary gifts and hospitality may be acceptable if they are of moderate value and do not affect business decisions, any arrangements that could influence business outcomes must be avoided.

Embezzlement, Cheating, or Theft: Misappropriation or unlawful taking of the Group's assets.

Violation of Laws and Regulations: Engaging in activities that breach legal or regulatory obligations.

Irregularities in Financial Reporting: Manipulation or misstatement of financial data.

Improper or Unauthorized Expenditures: Spending of company funds without proper approval.

Misuse of Funds and Resources: Using the Group's assets or resources for personal gain.

Abuse of Power or Authority: Using one's position to exploit or unfairly treat others.

Conflict of Interest Without Disclosure: Failing to disclose relationships or interests that could compromise the Group.

Breach of Internal Policies: Disregard or circumvention of the Group's established policies and procedures.

Aiding Illegal Activities: Supporting or facilitating unlawful actions by others.

Unauthorized Access or Disclosure of Information: Sharing confidential information without permission.

Concealment of Malpractice: Suppression of known wrongdoing within the Group.

Deception in Financial Audits or Reviews: Manipulating financial records during audits.

Endangerment to Health, Safety, or Environment: Engaging in activities that pose risks to safety or the environment.

Academic or Professional Malpractice: Violations of intellectual property rights or unethical practices in research.

Any Conduct Damaging to the Group's Reputation: Any actions that could cause financial or reputational harm to the Group.

4. Whistleblowing and Reporting Improprieties

The Group encourages all employees and stakeholders to report any concerns regarding corruption, bribery, or misconduct. Any suspected incidents of corruption or unethical behaviour should be reported to the Audit Committee at auditcommittee@mtq.com.sg.

All reports will be treated with strict confidentiality, and the identity of the whistleblower will be protected wherever practicable. The Audit Committee will oversee the investigation, ensuring that reports are reviewed discreetly and that appropriate follow-up actions are taken.

5. Investigations and Disciplinary Action

All reports will be thoroughly investigated, and appropriate actions will be taken, which may include disciplinary measures or termination. Serious cases will be reported to regulatory authorities if required.

6. Training and Communication

We provide regular training to ensure that all employees understand their responsibilities under this policy and adhere to our ethical standards.

7. Monitoring and Review

The policy is periodically reviewed to ensure its effectiveness. The Audit Committee is responsible for monitoring compliance and making recommendations for improvement when necessary.