HAFARY HOLDINGS is committed to disclose material information in a timely, transparent and accurate manner to the public, in accordance with listing rules of the Singapore Exchange Securities Trading Limited ("SGX-ST")
and the Singapore Code of Corporate Governance 2012.
1. PURPOSE & GENERAL PRINCIPLES
1.1
This Investor Relations Policy describes the principles and practices that the Company applies in order to provide current and prospective investors with information necessary to make well- informed
investment decisions and to ensure a level playing field.
1.2
All disclosures are submitted to Singapore Exchange Securities Trading Limited ("SGX-ST") through SGXNET, and are available on the Company's corporate website.
1.3
Unpublished material information is not selectively disclosed. On the rare occasion when such information is inadvertently disclosed, it will be immediately announced
to the public via SGXNET and the media.
1.4
This Policy is subject to regular review by the Company's Investor Relations Team.
2. COMMUNICATIONS GUIDELINES
2.1
The Company endeavours to provide clear, fair and balanced disclosure of pertinent information to its shareholders and the investment
community in a timely and effective manner.
(a)
be factual, clear and succinct;
(b)
contain sufficient quantitative information to allow investors to evaluate its relative importance to the activities of the Company;
(c)
be balanced and fair;
(d)
avoidover-technicallanguage;and
(e)
explain the consequences or effects of the information on the Company's future prospects. If the consequences or
effects cannot be assessed, provide the reason.
2.2
To the extent possible, all disclosures will:
2.3
Authorised Spokespersons
2.3.1.
The Company communicates only through designated senior spokespersons who will establish and maintain regular dialogue with shareholders to solicit and
understand their views, as well as respond to inquiries from members of the investment community or media.
2.3.2.
Employees who are not authorised spokespersons must not respond under any circumstances to inquiries from the investment community or media, unless
specifically authorised by designated senior spokespersons. Any inquiry received should be directed to the Investor Relations Team.
2.4
Responding to Market Rumours
As a guideline, the Company does not respond to rumours or market speculation. Clarifications will however be made promptly
through announcements via SGXNET in the event that material information is deemed to have been leaked or where there is
unusual market activities that could be attributable to such rumours or market speculation.
3. COMMUNICATION WITH SHAREHOLDERS AND INVESTMENT COMMUNITY
The Company employs various platforms to effectively engage the shareholders and the investment community, with an
emphasis on timely, accurate, fair and transparent disclosure of information. In addition to shareholder meetings,
the senior management of Company will also meet with investors, analysts and the media, as well as participate in
activities to solicit and understand the views of the investment community. The Company is committed to treat all
shareholders fairly and equitably, and keep all its shareholders and other stakeholders informed of its corporate
activities which would be likely to materially affect the price or value of its shares, on a timely basis.
3.1
Shareholders' Meetings
3.1.1.
The Company will facilitate opportunities for shareholders to participate effectively in and vote at shareholders' meetings and to put forth
any questions they may have on the motions to be debated and decided upon.
3.1.2.
The Company's AGMs are the principal communication channels with its Shareholders and for Shareholders' participation.
3.1.3.
All Shareholders are sent a copy of the Company's annual report with notice of AGM prior to the AGM. As and when an EGM
of the Shareholders is to be held, each Shareholder will be sent a copy of a circular with notice of EGM which contains details
of the matters to be proposed for Shareholders' consideration and approval.
3.1.4
Notices for the general meetings setting out the items of business to be transacted at the general meeting,
are also announced via SGXNET to SGX-ST.
3.1.5.
Members of the Board, the Company's senior management and the external auditors of the Company are in attendance at
all general meetings to address Shareholders' queries. A Shareholder is allowed to appoint up to two proxies to appoint up to two proxies to attend and vote at the general meetings on his/ her behalf.
3.1.6.
Shareholders will also be informed of the rules, including voting procedures that govern these general meetings.
3.2
Analysts and Investment Community
3.2.1.
The Company welcomes requests by analysts and institutional investors for meetings with senior management for the purpose of helping them to gain a broader understanding of the Company's businesses and
operating fundamentals. Any discussions at such meetings will be based on publicly available information.
3.2.2.
The Company will not influence the views or recommendations of analysts, brokerage firms and investment banks but may review an analyst's report for factual accuracy of information that is within the public domain.
3.3
Quarterly Results Announcements
3.3.1.
The Company releases quarterly results within 45 days of period end date and full year results within 60 days of period end date according to listing rules of the SGX-ST.
3.3.2.
The Company observes a "blackout period" of two weeks prior to the announcement of its quarterly results and one month prior to the announcement of its full-year results. During this period, the Company does not
comment on industry outlook, the Group's business performance and financial results.
3.4
Annual Report
The Company publishes an annual report to enable the shareholders and the investment community to obtain a comprehensive and consistent overview of its business strategies, developments and market outlook,
as well as operational and financial performance.
3.5
Corporate Website
The Company will make available all media releases, financial results, annual reports, SGXNET announcements
and other corporate information relating to the Hafary Group in the "Investor Relations" section of its corporate website
www.hafary.com.sg
4. PUBLICATION OF POLICY
This policy is available on the Company's corporate website at www.hafary.com.sg
Shareholders and the investment community can contact the Company's Investor Relations Team by telephone at +65 6383 2314,
fax at +65 6253 4496 or email at
ir@hafary.com.sg
1.1
Definition
A 'Whistle Blower' is an employee who submits a good faith complaint or concern to Hafary Group regarding
the detection of any unethical or illegal conduct within Hafary Group. Such conduct includes but is not limited to the following:
•
A wilful and unauthorised conduct which may cause financial or non-financial loss or damage to the Group, including loss of reputation;
•
A person abusing his official Hafary position in connection with unauthorised activity for financial or non-financial gain;
•
A failure to comply with a legal obligation (e.g. breach of a contractual or other common law obligation, statutory duty or requirement, malpractice or breach of a code of conduct); and
•
A criminal offence (e.g. corruption, fraud, theft).
1.2
Policy Objective
To achieve and maintain high standards with regard to behaviour at work, Hafary Group's employees are expected
to conduct themselves with integrity, impartiality and honesty. Among other measures to raise standards of
work ethics, Hafary seeks to develop a culture that encourages staff to challenge inappropriate behaviour at
all levels. The objective of this Policy is to provide a process for employees to raise, in confidence and
without fear of retaliation, occurrences of possible wrongdoing or breach of applicable laws, regulations or
policies, for appropriate investigation and action subject to applicable laws. In order to achieve this aim,
Hafary Board will use its best endeavours to ensure that any whistle blower who, in good faith report genuine
concerns about unethical or illegal conduct shall not, to the maximum extent possible, suffer from retaliation,
victimisation, harassment or adverse employment consequences. Hafary does not tolerate any retaliation,
victimisation or harassment (including informal pressure) of a genuine whistle blower and will treat such conduct
as one of misconduct, which if proven, may lead to a dismissal of the parties who carried out such misconduct.
2. PROCEDURES FOR WHISTLE BLOWING
2.1
Raising a Concern
•
Currently, staff can raise their concerns to their immediate supervisor for his attention and where necessary,
escalate their concerns, to their next level supervisors based on the internal organisational hierarchical level i.e.
the Supervisor, the Department Head and CEO.
•
In general, a whistle blower can raise his concern(s) in confidence using the existing internal
escalation channel i.e Financial Controller or Human Resources Manager. The members of the internal
channel should then raise the concern(s) to CEO (unless it is inappropriate).
•
Where there is concern that any members of the internal channel might be implicated or if staff deemed
it more appropriate, he can skip the internal escalation channel and raise his concern(s) directly to
the Audit Committee of Hafary Holdings Limited via
whistleblower@hafary.com.sg
2.2
Manners of Reporting and Investigations
•
A whistle blower is required to provide specific relevant details and factual information to support his concern(s)
expressed. This is to facilitate meaningful investigation. If insufficient
•
All submissions will be kept in strict confidence. Depending on the need, CEO or Chairman of the Audit
Committee may commission investigations to be conducted by independent persons, including board
directors, senior management, internal or external auditors or consultants as deem appropriate.
The members of the channel shall also determine the methods and procedures appropriate to investigate,
verify and act in relation to each submission received.
2.3
Confidentiality
•
Confidentiality of the identity of the whistle blower will, to the maximum extent allowed by law,
be maintained. In the event where the identity of the whistle blower is to be revealed, Hafary will
discuss this with the whistle blower before revealing the same.
•
Appropriate action, including disciplinary action may be taken against staff who retaliate against the whistle blower
•
If, however, a whistle blower makes an allegation frivolously, in bad faith, maliciously or for personal gain, Hafary Board may similarly take appropriate action, including disciplinary action against him.
1. INTRODUCTION
1.1
Hafary Holdings Limited and its group companies (collectively, the "Hafary Group", "we", "our", "us")
are committed to ensuring that your privacy is protected in your use and/or access of our website
(referred to herein as "this website").
1.2
This Privacy Policy outlines how we manage Personal Data (as defined below), which is subject to the
Personal Data Protection Act 2012 (the "PDPA") as may be amended, revised or re-enacted from time
to time.
2. WHAT IS PERSONAL DATA AND COLLECTION OF PERSONAL DATA
2.1
"Personal Data" refers to any data or information about you from which you can be identified either
from that data or from that data and other information to which we have or are likely to have access.
2.2
We may obtain Personal Data from you or your authorised representative and/or from a variety of
sources, including but not limited to, the following:
(a)
when you make online enquiries relating to our products and services through our website or
through an email address provided at our website;
(b)
when you register your interest in joining the Hafary Group as an employee by filling in the contact
form on our website and providing Personal Data including your name, contact number, email
address, current location, telephone number, and your curriculum vitae; and
(c)
when you submit your Personal Data to us for any other reasons.
2.3
Please note that visiting the website alone does not result in any personally identifiable data being
collected or stored.
2.4
This Privacy Policy shall also apply (with the necessary changes to be made) to Personal Data submitted
through hard copy order forms, trade-in purchase forms and warranty registration forms made to us.
3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
3.1
The purposes for which we collect your Personal Data include:
(a)
to provide you with any information, products or services that you may request or require;
(b)
to respond to your feedback or queries;
(c)
if you have subscribed to an email list, to send information about us, our products or services to your e-mail address;
(d)
for administrative, operation and/or internal purposes such as auditing, book-keeping and preparation of financial reports (including disclosure to auditors), data analysis, and research to improve our products, services, advertising, communications and other customer-related activities;
(e)
resolve any disputes; and/or in relation to any purchase or order of our products, to facilitate and/or process any such purchase or order (including billing, payment and settlement, delivery or collection of the products, etc); and
(f)
to monitor use of this website and to help its further development.
3.2
We may share your Personal Data with members of the Hafary Group (which includes our affiliates,
subsidiaries or joint ventures worldwide). We may also use and disclose your Personal Data as
permitted or required by the PDPA or any other law, including when we believe such disclosure to be
necessary to protect our rights and/or comply with any court order, request from a regulator or any
other legal process to which we are subject.
4. DATA QUALITY AND SECURITY
4.1
We will take reasonable steps to make sure that the Personal Data we collect, use or disclose is accurate, complete and up to date.
4.2
However, we are committed to ensuring that your information is secure. Once we have received your
information, we will take reasonable steps to protect the Personal Data we hold from misuse and loss
and from unauthorized access, modification or disclosure. We will not keep Personal Data for longer
than is necessary and will take reasonable steps to destroy or permanently de-identify Personal Data if it
is no longer needed. If you become aware of any security breach, please let us know as soon as possible.
5. WITHDRAWAL OF CONSENT, ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA
5.1
If you have any questions about this Privacy Policy or any complaints relating to your Personal Data, or
would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy,
or you would like to obtain access and make corrections to your Personal Data records (for which we
may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any
material requested), please contact:
Data Protection Officer
Tay Eng Kiat, Jackson
Operation Director
105 Eunos Avenue 3
Singapore 409836
Email: jackson@hafary.com.sg
6. REVIEW OF THE PRIVACY POLICY
6.1
We review this Privacy Policy regularly and may modify it from time to time without prior notice. Any
amendment, variation or supplement will be notified by publication on this website, effective from the
date of such publication. Your use of this website is subject to the most updated Privacy Policy in effect
at the time of your use.