GlobalRoam - Always In Touch

GlobalRoam Whistle Blowing Policy

PURPOSE

GlobalRoam Group Ltd (.Company.) encourages all employees to report to their management promptly any breach or suspected breach as defined under paragraph 2 (hereinafter also referred to as a "Breach"). Such reporting is commonly known as "whistle blowing".

The Company tries to achieve its business aims based on the principles of fairness, honesty, integrity and respect and accordingly wants to ensure that any employee or other stakeholders (such as customers or suppliers) who wishes to make a report of any Breach, which he or she reasonably believes to be true, can do so without the risk of retaliation; with the assurance that all reports are treated strictly confidentially will be promptly investigated and that reports can be made anonymously (if desired).
DEFINITIONS

In this policy the following terms shall have the following meanings:

(a) Breach: a suspicion based on reasonable grounds with regard to the Company and in connection with:
- a (imminent) criminal offence;
- a (imminent) violation of laws and regulations;
- an (imminent) intentional provision of incorrect information to public bodies;
- a violation of any GlobalRoam policies and guidelines;
- ny concerns regarding questionable accounting, internal accounting controls or auditing matters; or
- an (imminent) intentional suppression, destruction or manipulation of information regarding those facts;
(b) chairman of the Board: the chairman of the Board of the Company;

(c) Company: GlobalRoam Group Ltd and its associated companies and subsidiaries

(d) Compliance Officer: the person designated by the chairman of the Board to act in that capacity for the Company and its associated companies and subsidiaries

(e) employee: a person, employed or otherwise, working for the Company and associated companies and subsidiaries

(f) manager: the person directly managing the employee.

PROCEDURE

(a) Employees shall report a Breach internally to their manager or, if they consider reporting to the manager inappropriate, to;

	The Compliance Officer

	Phone:	+65 6349 5265
	Email:	wernyih@globalroam.com
	Letter:	GlobalRoam Group Ltd, 100 Lorong 23 (off Sims Avenue) D.centennial #08-01, Singapore 388398 Attn: Ng Wern Yih

(b) An employee may notify the chairman of the Board or chairman of the Audit Committee by contacting the Compliance Officer if the employee has concerns regarding Breach by members of Management or the Board.

(c) If an employee deems reporting the Breach to the Compliance Officer inappropriate because of his suspected involvement in the Breach, the employee may report to the Chairman of the Board or the Chairman of the Audit Committee:

	Chairman of the Board

	Phone:	+65 6296 5611
	Email:	micheal@holeegroup.com.sg
	Letter:	GlobalRoam Group Ltd, 200 Jalan Sultan Textile Centre #04-25, Singapore 199018 Attn: Micheal Tan

	Chairman of the Audit Committee

	Phone:	+65 6296 5611
	Email:	emily@tembusupartners.com
	Letter:	GlobalRoam Group Ltd, 151 Chin Swee Road Manhattan House, #04-08, Singapore 169876 Attn: Emily Goh

(d) The manager or the Compliance Officer shall make a written record of any report received in accordance with paragraph 3(a) and of the date of its receipt. The manager (through the Compliance Officer) or Compliance Officer shall procure that the Board be informed of a Breach and of the date on which it was reported, and he shall procure that the chairman of the Board receives a copy of the record.

(e) Immediately after the employee's report, investigation into the Breach will be started on behalf of the Board by the Compliance Officer and representatives of Human Resources Department.

(f) The employee who has reported a Breach shall keep the report confidential. No information shall be provided to third parties in or outside the Company and its associated companies and subsidiaries without the consent of the chairman of the Board. In providing information, the name of the employee shall not be disclosed and information shall otherwise be provided in such a manner as to safeguard where possible the anonymity of the employee.

(g) Within two weeks from his internal report, the employee shall be informed in writing, by or on behalf of the chairman of the Board, of the Board's position with regard to the Breach and the action taken as a consequence of the employee's report.

(h) If no position can be given within two weeks, the employee shall be notified thereof by or on behalf of the chairman of the Board and be given an indication as to when he will be informed of the Board's position.

REPORTING TO THE CHAIRMAN OF THE BOARD

(a) The employee may report the Breach to the chairman of the Board, if:

   i) he disagrees with the position referred to in paragraph 3(f) and 3(g);
   ii) he has not been given a position within the requisite period, as referred to in paragraph 3(f) and 3(g);
   iii) the Breach concerns a member of the Board of the Company;
   iv) the employee has reasonable grounds to fear that an internal report would lead to countermeasures;
   v) a previous, duly submitted, internal report about essentially the same irregularity, has not removed the irregularity;

(b) The chairman of the Board shall ensure that a written record is made of the report and of the date of its receipt.

(c) The chairman of the Board shall ensure that a confirmation of receipt will be sent to the employee who reported the Breach. If the employee had previously reported the Breach, the confirmation shall refer to the original report.

(d) Immediately after the employee's report, the Board shall start an investigation into the Breach in consultation with the Compliance Officer and the representatives of the Human Resources Department.

(e) The employee who has reported the Breach and the person to whom he has reported shall keep the report confidential. No information shall be provided to third parties in or outside the Company and its associated companies and subsidiaries without the consent of the chairman of the Board. In providing information, the name of the employee shall not be disclosed and information shall otherwise be provided in such a manner as to safeguard where possible the anonymity of the employee
REPORTING TO THE AUDIT COMMITTEE

(a) The employee may report the Breach to the Audit Committee if he has concerns regarding questionable accounting, internal accounting controls or auditing matters.

(b) The Audit Committee shall on request make a written record of the report and of the date of its receipt.

(c) The Audit Committee shall ensure that a confirmation of receipt will be sent to the employee who reported the Breach. If the employee had previously reported the Breach, the confirmation shall refer to the original report.

(d) Immediately after the employee's report, an investigation into the Breach will be started by or on behalf of the Audit Committee in consultation with the Chief Financial Officer of the Company, the Compliance Officer and the representatives of the Human Resources Department.

(e) The employee who has reported the Breach and the person to whom he has reported shall keep the report confidential. No information shall be provided to third parties in or outside the Company and its group companies without the consent of the Audit Committee. In providing information, the name of the employee shall not be disclosed and information shall otherwise be provided in such a manner as to safeguard where possible the anonymity of the employee.

(f) Moreover all Breaches reported by employees will be reported to the Audit Committee by the Compliance Officer on a quarterly base.
REPORTING TO COMMERCIAL AFFAIR DEPARTMENT ("CAD")

Anyone who suspects that an individual or company has committed offense(s) and believe that reporting to the above channels are not appropriate because the above parties are involved in the breech, may report the branch to the CAD. Reporting to CAD may be done by the following:

   (i) Lodge a complaint with any Neighborhood Police Centre
   (ii) Lodge a complaint with CAD via Written Complaint, Complaint in Person, or Complaint via Electronic Police Centre.
   (iii) More information can be found at CAD Website. (http://www.cad.gov.sg)
PROTECTION

No director, officer, employee or other stakeholders (such as customers or suppliers), who in good faith reports a Breach shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. The Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Company rather than seeking resolution outside the Company.
WARNING

The Company takes a serious view against reporting in bad faith or malicious reporting and will not hesitate to take actions against these reporting if they are unfounded.
EFFECTIVE DATE

These rules shall take effect. 10 December 2008.

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