GTS Whistleblowing Framework

GTS is committed to upholding the highest standards of integrity and ethical conduct. The GTS Whistleblowing Framework provides a secure and confidential platform for individuals to report any observed misconduct or unethical behavior involving GTS employees, business partners, or related parties—without fear of retaliation.

All whistleblowing reports will be independently reviewed and investigated by an Investigative panel led by Top Management of GTS. Investigation outcomes will be reported to the relevant regulatory authorities for further action, where necessary.

Whistleblowers are encouraged to report concerns in good faith. The identity of the whistleblower and the information provided will be kept strictly confidential unless disclosure is required by law or necessary for legal proceedings involving relevant authorities such as lawyers, law enforcement, or investigators.

Types of Reportable Improprieties

The following are examples of misconduct that should be reported under this framework:

1. Corruption & Bribery

Corruption or bribery involves the act of giving, receiving, offering, or soliciting any form of gratification to gain undue advantage. This may include, but is not limited to:

o Monetary rewards, gifts, or incentives

o Sexual favors

o Promises of special treatment, leniency, or contracts

o Preferential access to confidential information

2. Fraud

Fraud refers to any act of deception, concealment, or violation of trust for financial or personal gain.

Common forms of fraud include:

o Misappropriation of assets or funds

o Forgery or falsification of records

o Misuse of company information or resources for personal benefit

3. Unlawful Conduct

This includes all forms of illegal activities such as:

o Drug trafficking or abuse

o Physical violence or threats of harm

o Criminal damage to property

o Sexual harassment or workplace misconduct

o Money laundering and terrorism financing

How to Report a Concern

For allegations involving corrupt practices, reports should be made directly to the Police or Corrupt Practices Investigation Bureau (CPIB) at 1800-376-0000.

To enable GTS to effectively investigate concerns, whistleblowers are encouraged to email to feedback@global.edu.sg , stephen@global.edu.sg and provide the following details where possible:

o Your contact information (optional but preferred for follow-up)

o Name(s) of individual(s) or company(ies) involved

o Your relationship to the reported party

o A detailed description of the incident (including date, time, location, methods, and observed behavior)

o Duration of the alleged misconduct

o Whether management has been informed (if yes, include the date of notification and contact details of the person informed)

o Supporting evidence or documentation to substantiate the claim

o Whistleblowers are strongly encouraged to provide their names and contact details to facilitate a thorough and effective investigation.

o For more information or to submit a report, please contact General Manager at +65 8800 7666 and/or Senior Manager at +65 8279 0666.

Whistleblowers also have the option to report via electronic means as follow:

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