Whistleblowing Policy

United Hampshire US REIT (“UHREIT”) is committed to maintaining a high standard of integrity in its business conduct. The Manager of UHREIT, United Hampshire US REIT Management Pte. Ltd. (the “Manager”), has put in place a whistle-blowing policy to encourage employees or any other persons to raise genuine concerns about possible improprieties at the earliest opportunity in an appropriate way, without fear of reprisals and that their confidentiality will be respected.

Incidents of actual or suspected illegal and/or unethical conduct or violation of laws and regulations should be promptly reported to our independent whistleblowing channel.

WHISTLEBLOWING CHANNEL


All reports sent in via the whistleblowing channel email below will be directed directly to the Chairman of the Audit & Risk Committee (“ARC Chair”) and the Compliance Officer, to provide an independent reporting channel. This channel can be used by all employees and external parties, including suppliers, contractors, tenants and other stakeholders, to report any concern regarding irregularities or questionable behaviour of employee, service provider or associate. Confidentiality around the identity of the whistleblower is always maintained and will only be revealed upon permission from the reporter.

Email: whistleblowing@uhreit.com

HANDLING OF REPORTS RECEIVED


Upon receipt of the report, the ARC Chair may discuss with and have the matter investigated by the relevant management personnel, unless the whistleblowing report is related to that senior manager. Where the matter is found to be genuine and of financial and/or reputational significance to UHREIT, the ARC Chair will take steps to inform and discuss with the ARC and Board about the matter. After discussion with the Board and if directed by the Board, the ARC Chairman will take steps to have the matter further investigated by establishing a team comprising one or more of the following parties, including external legal counsels, (external) internal audit and forensic experts, depending on the incident reported.

Following the conclusion of the investigation, the whistleblower will be informed appropriately. The Manager will not tolerate any retaliation towards employees who report concerns and any employees taking action in response to a report will be subject to the disciplinary procedure.

This whistleblowing channel is not intended for the reporting of issues that are frivolous, trivial or non-factual in nature.

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