SOG Health Pte. Ltd. (“SOG Health” or the “Company”) is committed to build a diverse and inclusive culture in our organisation. At SOG Health, we recognise and embrace diversity, and views diversity at the Board level as an essential attribute in attaining our business goals and objectives.

The Board diversity policy statement aims to set out the approach to achieve diversity, in the first instance, on the Board of Directors (the “Board”) of the Company and in the second instance amongst the Specialist Medical Practitioners and senior management (“Management”) of the Company.

Diversity and inclusivity guard against group thinking, foster robust discussions which in turn leads to better decision making. SOG Health seeks to achieve and maintain diversity at both the Board and Management levels.

PURPOSE

This Policy has as its primary purpose, to the maintenance of the appropriate balance of perspectives, gender, ethnicity, age, background, skills and experience, sexual orientation, physical disability and any other differences on the Board and Management as the Board supports the long term success of SOG Health.

POLICY STATEMENT

To build a diverse and inclusive culture, the Board shall focus, but be not limited, to the following key areas:

• Recognise the importance of diversity and inclusivity.
• Committed to treating people with dignity and respect and ensuring a diverse and inclusive working environment at all levels of the Company.
• Develop measurable objectives, evaluate and critically assess progress at least on an annual basis. The evaluation shall be measured against internal and appropriate external targets.

In the implementation of the above, the Company shall:

• Highlight the essential diversity principles relating to appointments of Board members.
• Develop recruitment protocols and eliminate biases so that it can bring in the best people regardless of differences such as ethnicity, background, gender and age.
• Deliver fair and equitable performance management process that will help retain the best people, especially those who are different.

MEASUREABLE OBJECTIVES

The Board has established the following measurable objectives for diversity:

1. Maintain appropriate female representation (of at least 30% of total board composition) on the Board and Management.
2. Ensure the Board’s composition take into consideration other measurable attributes of the Board members such as skills, experience and other relevant aspects of diversity including the benefits of diversity which the Board members can bring to the Management.
3. In selecting Board candidates for appointment or re-election, the Board will not only consider core competencies namely the expertise, skills and experience of candidates, but also the manner in which candidates can enhance and complement the collective diversity of the existing Board.

The Board will assess these objectives annually, as well as the progress in achieving them.

MONITORING AND REPORTING

The Management reviews and monitors the implementation of this policy.

REVIEW OF THIS POLICY

The Management will review this policy to ensure its appropriateness and effectiveness. The Management will discuss any revisions that may be required and will subsequently recommend any such revisions to the Board for consideration and approval.

DISCLOSURE OF THIS POLICY

This policy will be published on the Company’s website for stakeholder’s information.

The Board of Directors (the “Board”) of SOG Health Pte. Ltd. (the “Company”) and its subsidiaries (together with the Company, the “Group”) seeks to conduct its business in an ethical manner and in compliance with best practice.

As a result, we have developed a Code of Ethics that we expect to continue to refine with various stakeholders. The underlying principle of the Code of Ethics is that we expect our management and staff to act with integrity towards those with whom we have business dealings, to the people in the society where we do business and towards each other. The Code of Ethics is over and above the Code of Medical Ethics and is designed to cover areas not covered by the Code of Medical Ethics and especially in the business and finance dealings of the Group. The Code of Ethics outlines how this principle is to be applied.

Our systems and processes are based on:

• Management and staff understanding that they are responsible and accountable for their own actions.
• Dealing honestly towards our investors, patients and customers, subcontractors, suppliers and other stakeholders, and not engaging in misleading or deceptive conduct.
• Treating all persons with dignity and in a manner that provides equal access and/or opportunity to all and which prevents harassment or discrimination.
• Respecting and complying with all applicable laws, regulations and local customs relating to behavioural and ethical practices, including consumer protection, trade practices, local social norms and operational health & safety matters.
• Where possible avoiding conflict of interest situations.

With Respect to Shareholders

In the exercise of their ownership rights, shareholders shall:

• View the Group from a medium and long-term perspective and not a short-term trading opportunity.
• Ensure that the Group maximises shareholder wealth in a:
  • Law abiding,
  • Socially acceptable,
  • Environmentally sustainable, and
  • Ethical & responsible manner.
• Ensure that they, the shareholders, have read the announcements and materials provided to them by the Group, so that they can exercise their voting rights in an informed and responsible manner; and in particular, with respect to their appointment of Directors who have the experience and the commitment to the Group and can perform their functions in a professional, ethical and responsible manner.
• Assist the Group to find a fair balance between capital and labour so that employees receive fair compensation for their work.
• Assist the Group to find a fair balance, between what is taken from the society and what is given back to society, to benefit the wider society.

With Respect to Directors and Management

In the exercise of their respective functions, they should:

• View the Group from a medium and long-term perspective and not a short-term employment or money-making opportunity.
• Ensure that the Group maximises shareholder wealth in a:
  • Law abiding,
  • Socially acceptable,
  • Environmentally sustainable, and
  • Ethical & responsible manner.

In relation to Management functions to:

• Act in a professional, ethical and responsible manner; and in particular, to avoid conflicts of interest. Where such conflicts are unavoidable, to resolve them in a transparent manner and for the interest of the Group.
• Comply and ensure compliance with all applicable laws, regulations and local customs relating to behavioural and ethical practices, including consumer protection, trade practices, local social norms and operational health & safety matters.
• Comply with accounting standards and to establish effective internal controls and good corporate governance practices.
• Comply and ensure compliance with the Group’s Code of Ethics.
• Provide stakeholders with adequate information about the Group, promote stakeholder participation and ensure that there are successors to continue the role of management of the Group.
• To act responsibly and reasonably to customers, sub-contractors, suppliers and providers of capital; and wherever possible, to choose business relationships that further achieve the objectives of the Group’s Code of Ethics.
• To treat all individuals, particularly employees, fairly and with dignity and in a manner that provides equal access and/or opportunity to all and avoids any harassment or discrimination situations.
• Wherever possible to promote the interest of the society in which the Group operates.

With Respect to Employees

• Employees should be informed that they have rights and responsibilities.
• Employees should make themselves aware of their rights and understand that they are accountable for their actions.
• Employee rights shall include:
  • Being treated with dignity, respect and in a culturally appropriate manner.
  • Being employed in an operationally safe environment.
  • Not being discriminated against 1, harassed or be placed in a position of abuse or violence.
  • Fair remuneration for the job done or responsibility assumed.
  • The right to communicate with management in matters where they feel their rights have been breached; and the Lead Independent Director or the Chairman of the Audit Committee, in private, where the Group’s Whistle Blower code applies.
• Employee responsibilities shall include:
  • Abiding with all relevant laws and helping the Group to promote this Code of Ethics.
  • Not abusing or using the Group’s assets and resources for their own benefit.
  • Dealing fairly and honestly towards the Group’s customers, subcontractors and suppliers, and not engaging in misleading or deceptive conduct.
  • Treating all persons, particularly managers, fellow workers and the local population with dignity and respect.

By age, disability, features, genetic, nationality, pregnancy, race, religion, sex or sexual preference.

SOG Health Pte. Ltd. (“SOG Health”) and its subsidiaries (collectively, the “Group”) is committed to maintaining high standards of honesty, openness and accountability.

• As employees (including Specialist Medical Practitioners) will usually be the first to know when someone inside or connected with the Group is doing something illegal, dishonest or improper;
• As many employees may feel apprehensive about voicing their concerns; and
• As the Board does not believe that it is in the interest of the Group to keep such knowledge silent.

The Group has adopted a Whistleblowing Policy and the following sets out the policy and procedures by which you can report your concerns. The Whistleblower can be assured that the information will be examined carefully and if it has merit will be acted on. The whistleblower (internal and external) can be assured that the Group intends to protect its business and reputation.

Policy Statement

SOG Health takes all malpractice very seriously, whether it is committed by an employee, supplier customer, competitor or contractor.

This Policy Statement applies to all employees, agents and consultants. It is intended to complement statutory protection and, for the avoidance of doubt, statutory rights will not be affected in any way by this policy.

The following examples demonstrate what we mean by serious malpractice:

• Fraud, corruption, bribery or other malpractice that could lead to a financial or reputational loss to the Group.
• Criminal offences such as theft, unlawful use of Group’s assets, and abuse of patient information (i.e. breach of Privacy Policy and Personal Data Protection Act).
• Breaches relating to the accuracy or integrity of the Group’s financial statements.
• Failure to comply with the law or legal obligations.
• Actions which are intended to conceal any of the above.

If you become aware of any such activities or other possible malpractices, you are encouraged to follow the procedures set out below. It will not always be clear that a particular action falls within one of these categories, and you will need to use your own judgment. However, if you believe the matter to be serious, SOG Health would prefer you to report your concerns rather than keep them to yourself.

Procedures

How do I make a report?

You can make a report orally or in writing. Normally, for employees, you should inform your immediate manager, or their line manager.

Historically, a whistleblowing channel through email has been implemented. With effect from February 2018, the Company has assessed the need to have more than one whistleblowing channels and our stakeholders can now use any of the following whistleblowing channels:

1. Whistleblowing Channel
   info@sog.com.sg
2. Auditors
   Nexia Singapore PAC
   Attention to Audit Partner-in-charge: Mr Koh Wee Kwang
   weekwang.koh@nexiasingapore.com

Do I need proof of wrongdoing to make my report?

SOG Health does not expect you to have absolute proof of any malpractice that you report. However, you will need to be able to explain the reasons for your concern. Whilst the Group wishes to encourage whistleblowing, it will not tolerate spurious or vindictive allegations.

How will my report be investigated?

Once you have made a report, an unrelated (to the incident or person being reported) SOG Health senior management will acknowledge receipt of it within 10 working days.

An independent person will then make preliminary enquiries as confidentially as possible. If the person raising the concern is required to attend face-to-face meeting, a fellow employee may accompany him or her where appropriate.

If it is determined that a fuller investigation is necessary, this will proceed either with further internal investigations, or by referral to an appropriate external body, dependent upon the nature and the seriousness of the report.

Will SOG Health protect my identity if I make a report?

If you make a report, SOG Health will do everything possible to keep your identity as confidential as possible during the investigation and you may assume that only the SOG Health person investigating the malpractice concern will know your identity. However, there may be circumstances (for example, if your report becomes the subject of a criminal investigation) where you may be needed as a witness and, once the investigation is complete, the findings may need to be communicated to the individual(s) concerned (see below). Should this be the case we will discuss the matter with you at the earliest opportunity.

Can I protect my identity by reporting on a confidential basis?

The Group would prefer you to give your name and contact details when you make a report. However, you are also allowed to communicate your concern on a confidential basis.

What will happen on completion of the investigations?

Subject to any legal constraints, SOG Health will communicate the findings of the investigation to:

You as the person raising the report;
The individual(s) under investigation; and
If appropriate, SOG Health senior management or external authorities who need to consider whether action should be taken on the basis of the findings.

As with any case where an employee is found to be involved in wrongdoing, they will be dealt with effectively in accordance with employment laws and contracts of employment.

Am I at risk of suffering victimisation if I raise a report?

You can be assured that, if you raise an important concern, this will be taken seriously and you will be treated fairly and with discretion. We will take all reasonable steps to ensure that no person under our control engages in victimisation of any form. If you make a report in good faith, even if it is not confirmed by an investigation, your concern will be valued and appreciated and you will not be liable to disciplinary action. However, if you make a false report, maliciously or for personal gain, then you may face disciplinary action.

What can I do if I am unhappy with the way SOG Health has dealt with my report?

If you are unhappy with the outcome of an investigation, you should submit another report explaining why this is the case to the whole of the Board of Directors. Your concern will be investigated again if there is a good reason to do so.

If you are still unsatisfied with the result, you may make a report to any other Singapore authorities you wish.

This is the personal data protection policy of SOG Health Pte. Ltd.  The terms “we”, “us” and “our” refer to SOG Health Pte. Ltd. (“SOG”) and all the clinics under the Group.

We will follow this policy and comply with all data protection and confidentiality obligations imposed by the law including the Personal Data Protection Act and Private Hospitals and Medical Clinics Act (Cap. 248) of Singapore.

Type of personal data collected

Under this policy, personal data refers to information that can be used to identify a person. Examples of personal data include but are not limited to the following: your name, nationality, date of birth, gender, contact details (including address, email address and telephone numbers), NRIC/FIN or passport number, nationality, your image on our close-circuit television (“CCTV”) and in photographs, your medical history, allergy information and any other medical records.

Should you provide the personal data of other people such as your next-of-kin or other family members, it is deemed that you have obtained the consent of the said party to our collection, use and disclosure of his/her personal data for the purposes outlined in this policy.

Our reasons for collection, use and disclosure of personal data

We collect, use and disclose personal data for the following purposes:

Medical Care

• Provision of outpatient and inpatient medical treatment and services.
• Management and coordination of your care including clinic follow-up and other matters related to the continuity of care.

Providing customer service

• Provision of products and services as requested.
• Responding to queries or feedback.
• Addressing or investigating complaints, claims or disputes.

Administration

• Processing of appointments, bookings of services, admissions, referrals and discharge.
• Processing and collecting payment for treatment and services.
• Reimbursement from healthcare providers for services provided to you.
• Verification of identity and conduct of screenings, due diligence checks and credit checks.
• Responding to queries or feedback.
• Provisions to allow us to address and investigate any claims or disputes.
• Compliance with internal policies.
• Compliance with our legal obligations and requirements.
• Creation, storage and backup of customer (patient) records for financial or business purposes.

Business Operations

• For the safety and security of our premises.
• For business analytics and planning purposes.
• For the review of our services and to ensure continual care.

Marketing and Promotion

• Sending of marketing and promotional materials with your consent by SOG Health and our partners.
• Telemarketing messages will not be sent to your contact number unless we have your recorded permission to do so.

Photography and CCTV

• Photographs, videos and/or sound recording may be captured in our premises from time to time and there is a chance that you may be captured in such photographs and recordings.
• The photographs and/or recordings may be used in our publications, websites and other communication channels that can include third party media.
• CCTV may also be in operation around our premises due to the interests of safeguarding our premises.
• Any other purposes relating to or arising out of the above.

Your personal data may be disclosed to third parties, who may be located in Singapore or elsewhere to achieve the purposes outlined in the policy. The third parties include but are not limited to the following:

• Doctors and other healthcare professionals who are treating or have treated you.
• Our respective partners for the provision of products and services that are requested by you or for the conducting of marketing/promotions with your expressed consent.
• Third parties that you have used to obtain our services such as medical concierges, insurance agencies, business associates, any other agencies or similar service providers.
• Other healthcare providers, facilities or other agents where the sharing of information is required for disclosure permitted by the law.
• National registers and databases that document various conditions and treatments where required and permitted for disclosure by the law.
• Any person who is involved in your care or payment for your care (including a family member, friend or your caregiver or caregiving organisation) and any person that has been authorised by you to be contacted.
• Any other regulatory authorities for the purposes of complying with the law.

We may also collect, use and disclose personal data where required or permitted by law for any other purposes.

Retention of personal data​

Your personal data will be retained for a reasonable amount of time in accordance with our business and legal policies.

Amendments and updates

This policy will be amended from time to time and will be made available via the SOG Health website www.sog.com.sg. The latest policy will be enforced each time personal data is collected, used or disclosed.

Contact us

If you have questions or concerns regarding your personal data or any aspect of this policy, please contact our SOG Health Data Protection Officer at dpo@sog.com.sg.

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