Whistle-Blowing Policy

This whistleblowing policy (the “Policy”) applies to all directors, officers, employees, including full-time, part-time and contract employees of Darco Water Technologies Limited (the “Company”) and the subsidiaries and associates of the Company (together with the Company, the “Group”), whether located in Singapore or elsewhere, or and any other external parties who have dealings with the Group.

The Group is committed to the highest possible standards of ethical, moral and legal business conduct. In line with this commitment and the Group’s commitment to open communication and good corporate governance, this Policy aims to provide a framework by which employees as well as external parties who have dealings with the Group may raise concerns about wrongdoing or malpractice within the Group and to reassure the whistle blowers that they will be protected from reprisals or victimisation for whistle blowing in good faith and without malice.

The Policy is intended to cover concerns over wrongdoing or malpractice within or by the Group (“Alleged Wrongful Act”), including, without limitation, actions that:-

• may lead to incorrect financial reporting;
• may be questionable accounting or auditing matters;
• are unlawful;
• are in breach of a legal obligation or contrary to any Group policy;
• may pose dangers to the health and safety of an individual;
• may damage the environment;
• may amount to professional or ethical malpractices;
• conceals wrongdoings or malpractices;
• may pose breach of fundamental internal control;
• misappropriates assets or funds of the Group;
• pertain to a substantial conflict of interest without disclosure;
• are in violation of this Policy;
• otherwise amount to improper conduct; or
• deliberately conceal information tending to show any of the above.

Harassment or Victimisation

Harassment, or victimisation of the whistle blower solely in retaliation for raising concerns over an Alleged Wrongful Act will not be tolerated and appropriate steps will be taken to ensure the whistle blower suffers no detriment, retaliation, or unfair treatment as a result of raising concerns over an Alleged Wrongful Act.

Victimisation includes termination of employment; demotion; suspension; written reprimand; retaliatory investigation; decision not to promote; receipt of an unwarranted performance rating; withholding of appropriate salary adjustments; elimination of the employees’ position, absent an overall reduction in work force, re-organisation, or a decrease in or lack of sufficient funding, monies, or work load; or denial of awards, grants, leaves or benefits for which the whistle blower is then eligible, or discrimination or threats of any form.

Every effort will be made to protect the whistle blower’s identity and ensure its confidentiality, subject to the exceptions as set out below. All matters discussed during whistle blowing investigation meetings and all information that comes into the possession of the Audit Committee of the Company (the “Audit Committee”), investigation team or any other relevant person are to be kept confidential.

However, it is important to be aware that it may be necessary to reveal the identity of the whistle blower, to assist with the investigations under certain circumstances, or to comply with relevant laws, such as:

1. Where the Group is under a legal obligation to disclose information provided;
2. Where the information is already in public domain;
3. Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice in connection with the investigations; and/or
4. Where the information is given to the Police or other authorities for criminal investigations.

In the event we are faced with a scenario not covered by the above, and where the whistle blower’s identity is required to be revealed, we will inform the whistle blower prior to such disclosure.

The Policy encourages whistle blowers to put their names to allegations because appropriate follow-up questions and investigations may not be possible unless the source of the information is identified. All concerns will be treated with strict confidentiality. Concerns expressed anonymously will still be investigated, but consideration will be given to:

• the seriousness of the issue raised;
• the credibility of the concern; and
• the likelihood of confirming the allegation from attributable sources.

Whistle blowers who raise a concern in good faith, which is shown to be unsubstantiated by subsequent investigation, will not have action taken against them. However, a whistle blower who makes an allegation maliciously, for personal gain or knowing it to be untrue or unfounded, may be dealt with disciplinarily.

All reports of Alleged Wrongful Acts should be reported through email to:

Chairman of the Audit Committee

DARCO WATER TECHNOLOGIES LIMITED

Email address: WhistleBlow@darcowater.com

To ensure that the whistleblowing report can be submitted confidentially or anonymously, the whistle blower may indicate “Private and Strictly Confidential” in the subject of his email.

A report should be sufficiently detailed, setting out the background and history of events and reasons for the concern so as to provide the necessary information to the Chairman of the Audit Committee as to the nature of the Alleged Wrongful Act. Although the whistle blower is not expected to prove the truth of an allegation, the whistle blower is encouraged to provide such evidence as to demonstrate that there are sufficient grounds for concern.

The Group assures all whistle blowers that any concern raised on information provided will be investigated, but consideration will be given to these factors:

• Severity of the issue raised;
• Credibility of the concern or information; and
• Likelihood of confirming the concern or information from attributable sources.

The action taken following receipt of the whistleblowing report will depend on the nature of the concern. Preliminary inquiries will be made to determine whether an investigation is appropriate, and the form that it should take on. Some concerns may be resolved without the need for investigation.

The Audit Committee has been designated as the independent function to investigate whistleblowing reports made in good faith. Upon receiving a complaint, the Audit Committee shall:

1. determine whether the matter falls within the scope of this Policy and whether an investigation is appropriate; and
2. if deemed appropriate, determine the investigation team lead and team members who shall be in charge of conducting the investigation, or to refer the matter to management for investigation.

The Audit Committee shall maintain a record of all complaints received together with the actions taken thereto and this report shall be presented at its meetings. The Audit Committee shall review the report and direct further actions to be taken as it deems necessary.

The Audit Committee shall also maintain a record of concerns raised under this Policy, circulate the concerns and form up an opinion, and maintain the outcomes, and will report as necessary to the Board of Directors.

Subject to legal constraints and to the guidelines of this Policy, the whistle blower will be given the option to receive follow-up notifications regarding his concern within a reasonable time of the complaint:

• acknowledging that the concern was received; and
• indicating how the matter will be dealt with.

The amount of contact between the whistle blower and the body investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from the whistle blower.

Subject to legal constraints, the whistle blower will receive information about the outcome of any investigations.

A copy of this Policy and any subsequent amendments or modification thereof, shall be made available by the administration department / HR department to all directors, officers, employees, including full-time, part-time and contract employee of the Group, through publication at the notice board / website of the Group companies or such other means as may be approved by Audit Committee.

Approved and adopted by the Audit Committee on 24 February 2025.

Approved by the Board of Directors on 24 February 2025.

The Audit Committee has the responsibility for ensuring the maintenance, regular review and updating of this Policy. Revisions, amendments and alterations to this Policy can only be implemented upon approval by the Audit Committee and the Board of Directors. Changes will be notified in writing to the whistle blowers when they occur.