Robin Lynn & Lee (“Firm”) is committed to a high level of integrity and propriety in all its business activities and operations.

We do not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by our personnel. To promote the disclosure of information about any misconduct within the Firm or our vendors, the Firm has in place a Whistleblowing Policy which sets out the framework to promote responsible and secure whistleblowing by affording protection to the whistleblower.

Reports

Whistleblowing is the deliberate voluntary disclosure, or reporting of inappropriate, unethical or unlawful behaviour, and organisational malpractices by an employee (which includes management). Such behaviour could be actual, suspected, or anticipated.

We encourage anyone who is aware of any wrongdoing committed by our employees or representatives to disclose it to us. This includes former employees and any other persons providing services to the Firm. Unless required by law, the identity of the whistleblower will be kept in strict confidence and will not be disclosed without the consent or approval of the whistleblower.

You can make a confidential report of improper behaviour in writing by providing the details relating to the incident, including the parties involved, the venue, the time, witnesses, supporting evidence where available, and any other relevant details. You are encouraged to provide your name and contact details for the investigating team to contact you.

Please make such reports to whistleblowing@robinlynnlee.com.

Investigations

The Compliance Officer will conduct a preliminary investigation of the report. Such decision and recommendation will be referred to a central committee for a decision to close the case or proceed to a full investigation of the allegations. Any persons named as a subject matter of the report is barred from taking part or being involved in any part of the investigation. The results and recommendations of the full investigation will be reported the central committee. If the outcome results in a proven case of wrongdoing and confirms the allegations, relevant actions will be instituted against the related persons in accordance with our policies.