144 UNITED HAMPSHIRE US REIT Corporate Governance WHISTLEBLOWING POLICY UHREIT acknowledges the importance of lawful and ethical behaviour in all its business activities and is committed to adhering to the values of transparency, integrity, impartiality and accountability in the conduct of its business and affairs in its workplace. The Manager has in place a Whistleblowing Policy which allows its employees and any other persons to raise concerns about possible improprieties with the confidence that they will be treated fairly and without fear of reprisal. The Whistleblowing Policy serves to ensure that arrangements are in place for concerns to be raised and independently investigated, and for appropriate follow-up action to be taken. Such concerns may include matters relating to financial reporting and other malpractices including fraud, corruption, bribery or blackmail, criminal offences, failure to comply with a legal or regulatory obligation, miscarriage of justice, endangering the health and safety of an individual and concealment of any of the aforementioned. Whistleblowers can submit their reports directly to the ARC Chairman via a dedicated whistleblowing email account published available on UHREIT’s website. Whistleblowers are given the option to remain anonymous and all information provided is kept in the strictest confidence. The ARC is responsible for oversight and monitoring of whistleblowing reports submitted via the whistleblowing channel to the ARC Chairman. Every report received, whether anonymous or otherwise, will be assessed by the ARC Chairman and the Compliance Officer. They will review the information, interview the whistleblower when required, and if contactable, and make recommendations to the ARC as to whether the circumstances warrant an investigation. If the ARC determines that an investigation should be carried out, the ARC will determine the appropriate investigative process to be employed. The outcome and findings from the investigation will be reported to the ARC including recommendations on any corrective or remedial actions to be taken. The ARC will determine the adequacy of corrective or remedial actions taken. The Board will also be informed about the whistleblowing report and the results of the investigations as well as corrective actions undertaken. Establishing these policies reflects the Manager’s commitment to conduct its business within a framework that fosters the highest ethical standards. The Whistleblowing Policy is made available to all employees when they join the Manager, and they are briefed on this. DEALING IN UNITS The Manager has adopted a security dealing policy for the Manager’s Directors and employees which follows the best practice recommendations in the Listing Manual. Employees of the Manager are required to seek prior approval before dealing in the Units of UHREIT. Directors and employees of the Manager are also prohibited from dealing in the Units (a) in the period commencing two weeks prior to the announcement of UHREIT’s operational update in the first and third quarters, and one month before the announcement of UHREIT’s half year and full year financial statements; and/or (b) at any time while in possession of price sensitive information. Prior to the commencement of each relevant period, an email would be sent out to all Directors and employees of the Manager to inform them of the duration of the period. The Manager will also not deal in UHREIT’s Units during the same period. Each Director and the CEO of the Manager is to give notice to the Manager of (a) particulars of Units held by him or her, or in which he or she has an interest and the nature and extent of that interest within two Business Days after the later of; (i) the date on which the director or Chief Executive Officer becomes a director or Chief Executive Officer; or (ii) the date on which the director or Chief Executive Officer becomes a holder of, or acquires an interest in the Units; or (b) of changes in the number of Units which he or she holds or in which he or she has an interest, within two Business Days after the director or Chief Executive Officer becomes aware of the change. All dealings in Units by the Directors and/or the CEO of the Manager will be announced via SGXNET.
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