In continuous demonstration of Senior Management’s commitment to transparency and high ethical standards, the whistle blower policy has been redesigned to align with the Code of Business Conduct and Ethics for increased efficiency in addressing misconduct and ethical violations by FGI representatives.

Purpose: To provide confidential and anonymous channels for reporting suspected violations of the Code of Business Conduct and Ethics by FGI Industries Ltd. or its representatives.

Channels: There are three channels through which reports can be made.

Reports can be shared via the telephone line indicated above. Callers will be asked to leave a voice message with as many details as possible and indicate if they would like to be anonymous or willing to provide contact details for personal feedback and/or to assist in investigation if necessary.

Concerns can be shared through an email to Ethics@FGI-Industries.com

Reports can also be shared online by visiting our website and locating our ethics hotline link. Clicking the link displays an online form to be completed with the reports.

 

All whistle blowing reports will be received by members of the Audit Committee of the Board of Directors (AC) regardless of the channels through which they are sent.

Scope: Concerns expected to be reported through the revamped whistle blower scheme include the following.

• • Non-compliance with Regulatory and Legal obligations.
  • Fraud, Theft, Bribery and Corruption.
  • Misrepresentation in Financial Reporting.
  • Concealment of perceived financial misconduct.
  • Miscarriage of Justice.
  • Retaliation.
  • Escalation of other reported cases deemed unsatisfactorily treated.

Note that existing channels remain available for reporting concerns such as Investorrelations@FGI-Industries.com for investor relations enquiries, Division and Country Heads direct emails or Customer service emails such as Contrac@FGI-industries.com, CustomerService.CDN@FGI-Industries.com for customer service complaints and Anca.Toth@FGI-Industries.com for employee related grievances.

Principles:  

• • Good Faith: There will be no victimization or retaliation for reports made in good faithwith reasonable grounds for believing that violation has occurred. However, a person who makes an allegation maliciously or with good reason to believe that the allegation was false may be subject to disciplinary and/ or legal action.
  • Investigation: All reports will thoroughly go through a fair, impartial and confidential investigation. Appropriate action will be taken against individuals who are found to have violated the Code of Business Conduct and Ethics or other FGI policy, up to and including termination of employment and/or cessation of contracts for representatives.
  • Confidentiality: Reporters of suspected violations are encouraged to identify themselves when making a report to facilitate investigation of the concern. However, they are at liberty to report anonymously, in which case, there will be no attempt to ascertain their identities, and the report will be treated confidentially.
  • No Retaliation: No Representative or member of the public who in good faith reports a suspected violation or cooperates in the investigation shall experience retaliation as a result of the report. Any suspected retaliation should be separately reported to the AC for investigation.

Reporting Requirements: To facilitate investigation, reporters are encouraged to share as much information as possible including the underlisted details where possible.

• •  Description of Incident/observation
  •  Names of person/people involved
  •  Branch or Location of Person(s) involved
  •  Location where observation was made
  •  Date and Timing
  •  Any other relevant information

Internal Procedure for Investigating Reports

1. 1. The Audit Committee is responsible for overseeing the receipt, retention and investigation of and response to all reports. When a report is received, an initial screening is carried out by the AC to assess if the report may be considered ethical misconduct. Where concerns are assessed to be ethical misconduct in line with the policy, they are delegated to a relevant member of Company management who is not the subject of the report, for example, the Internal Control Auditor, Controller or Human Resources Director to assist in the investigation.
   2. Non ethical misconduct reports may be forwarded to a relevant member of Company management who is not the subject of the report in line with established guidelines.  For example, Harassments and Grievances to Human Resources Director, Customer Services related issues to Country/ Divisional Heads and Investor Relations matters to Investor Relations. Additionally, independent legal, accounting or other advisors may be retained as necessary or appropriate.
   3. Where possible, the report is promptly acknowledged to the reporter as receiving attention while being told that additional information may be requested to facilitate the investigation.
   4. The reporter is not expected to attempt to investigate the concern and allow the investigation to proceed as objectively and independently as possible without interference.
   5. Investigations shall be conducted fairly and impartially, and investigation reports with recommendation presented to the AC in a timely manner upon conclusion.
   6. The AC will take appropriate action upon considering all evidence gathered and the recommendations as presented. The AC will assess the findings independently and may engage external advisors where necessary in arriving at the final course of action.
   7. Detailed Records of all reports will be maintained and archived with limited access for at least 8 years. Identities of reporters and personal data in the reports and communication shall be anonymized where possible to prevent possible retaliation.

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