This GenZero SpeakUp Policy (“Policy“) has been developed for GenZero1, being Carbon Solutions Holdings Pte. Ltd. and its direct and indirect subsidiaries (together the “Company” or “GenZero“)2.

To raise a concern, you may make a report via our independent whistleblowing service on our SpeakUp Platform (access here).

If you have any questions, you may write to: [email protected]

Scope
GenZero has established this Policy which sets out avenues for legitimate concerns to be objectively investigated and addressed. Individuals are able to raise concerns about illegal, unethical, or questionable practices in confidence and without the risk of retaliation.

1. So, what is SpeakUp?
SpeakUp is the voluntary reporting or disclosure of inappropriate, unethical, or unlawful behaviour and practices by GenZero’s Board Directors or employees. This Policy also sets out clearly how any reports received are treated.

2. Who should raise a concern?
Anyone has the right to SpeakUp. This includes Board Directors, employees (irrespective of nature of employment status), partners, lenders, financiers, and any other stakeholders/persons providing services to GenZero, including consultants, vendors, independent contractors, external agencies, and/or any other party with a business relationship with GenZero.

3. Obligation to Report Misconduct
Employees must act in accordance with GenZero’s guiding principles and policies, and perform their duties with honesty and integrity in all areas.

Employees or any party referred to in paragraph 2 are encouraged to report any work-related conduct which appears inappropriate or unlawful.

Examples of misconduct include:

    • Actions that violate the law
    • Fraud, theft, improper accounting, money laundering, or false claims
    • Corruption, conflicts of interest, kickbacks, and bribery
    • Unfair competition and insider trading
    • Actions that pose serious environmental risk
    • Actions that endanger health, safety, labour, or civil rights
    • Breach of data protection, confidentiality, privacy, or IT security
    • Improper interpersonal behaviour such as violence, discrimination, harassment, and sexual harassment
    • Any other conduct that violates or encourages other employees to violate our Code or policies

4. How to report misconduct?
We encourage employees or any party referred to in paragraph 2 to report concerns of misconduct through any of the below channels.

A report can be made to any of the following dedicated channels:
4.1 Employee can discuss and/or report directly to your manager.

4.2 Concerns can be reported to the General Counsel or the Director, Human Resource.

4.3 Write to a dedicated compliance mailbox at the following e-mail address: [email protected]

4.4 Make a report via our independent whistleblowing service on our SpeakUp Platform (access here).

5. How does GenZero handle the information provided by you?

5.1   GenZero commits to ensure that all disclosed information, including the identity of the reporter shall be treated with strict confidentiality. All personnel, directly or indirectly working relative to a SpeakUp case, shall strictly protect the identity of the reporter and witnesses from unauthorised disclosure before, during and after any investigation.

5.2   After receiving the report, GenZero will strive to review and assess the matter promptly in accordance with our internal policies and procedures. All investigations will be conducted with strict confidentiality and impartiality.

5.3   GenZero is committed to a workplace culture where employees feel safe to raise concerns at any time without fear of retaliation. Employees must not retaliate against anyone who filed a report in good faith or participated in an investigation. GenZero’s anti-retaliation protection extends to employees, third party reporters, witnesses, persons who assisted the reporter in the investigation process, and persons connected with the reporter who could suffer retaliation. Acts, threats, or attempts of retaliation are a serious violation of GenZero’s policies and will be investigated. Anyone found to have engaged in retaliation will be subject to disciplinary action, up to and including dismissal.

5.4   All records will be retained and kept strictly confidential by the General Counsel, in accordance with GenZero’s internal document retention policies.

6.  Responsibility of a reporter:
(a)   To make the disclosure in good faith.
(b)   To reasonably believe that the information and allegations are substantially true.
(c)   If the case involves the reporter’s personal interests, it must be informed at the outset.

 

1The terms “subsidiary” and “subsidiaries” are as defined under the Companies Act 1967 of Singapore.
2The companies in which Carbon Solutions Holdings Pte. Ltd. directly and indirectly owns investments are separate legal entities. In this Policy, “GenZero” and “the Company” are sometimes used for convenience where references are made to Carbon Solutions Holdings Pte. Ltd. and its subsidiaries in general. Likewise, the words “we”, “us” and “our” are also used to refer to GenZero companies in general or those who work for them.