1. Purpose
Mobile Community Tech Pte Ltd (“MCT Pay” or “the Company”) is committed to the highest standards of integrity, transparency, and ethical conduct. This Whistleblower Policy provides a framework for employees, contractors, business partners, and other stakeholders to report concerns regarding suspected misconduct, unethical behavior, or violations of laws and regulations, in a confidential and secure manner without fear of retaliation.
2. Scope
This Policy applies to all employees, officers, directors, vendors, consultants, and other stakeholders who have a business relationship with MCT Pay.
3. Reportable Concerns
Concerns that should be reported under this Policy include, but are not limited to:
• Fraud, bribery, or corruption
• Breaches of legal or regulatory obligations (e.g., Monetary Authority of Singapore regulations)
• Insider trading or misuse of confidential information
• Misappropriation of company assets or funds
• Harassment, discrimination, or unsafe work practices
• Breaches of internal controls or Code of Conduct
• Any attempt to conceal or suppress information relating to the above
4. Reporting Channels
MCT Pay offers multiple, secure channels for whistleblowing:
• Email: compliance@mctpay.sg
• Whistleblower Hotline: [+65 9850 1098] (available 24/7)
• Postal Mail: Marked “Private & Confidential” to Head of Compliance, Mobile Community Tech Pte Ltd, [10 Anson Road #15-20 International Plaza Singapore 079903]
Reports may be made anonymously; however, providing contact information may help facilitate further investigation.
5. Investigation Process
• Upon receipt of a report, the Head of Compliance (or designated officer) will acknowledge and assess the allegation to determine if an investigation is warranted.
• If appropriate, an internal or external investigation team will be appointed.
• The investigation will be conducted promptly, objectively, and discreetly, ensuring fairness to all parties.
• Findings and recommended actions will be reported to senior management and/or the Board of Directors where necessary.
6. Protection of Whistleblowers
MCT Pay strictly prohibits retaliation against any individual who, in good faith, raises a concern under this Policy. Any act of retaliation will be treated as a serious disciplinary offence and may lead to termination of employment or business relationships.
7. Confidentiality
All whistleblower reports and related information will be kept confidential to the extent permitted by law and necessary to conduct a proper investigation.
8. False or Malicious Allegations
Deliberately making false or malicious allegations is a serious offence. Appropriate disciplinary or legal action may be taken against any individual found to have made a report in bad faith.
9. Record Keeping and Reporting
The Compliance Department will maintain a secure log of all whistleblower reports, investigations, and outcomes. Summary statistics may be reported to the Board and, where relevant, the Monetary Authority of Singapore (MAS), without revealing identities unless legally required.
10. Review of Policy
This Policy will be reviewed annually and updated as needed to ensure its continued effectiveness and compliance with applicable laws and regulations.
