Dispute Resolution Policy

Purpose

The Dispute Resolution Policy provides a structured framework for the timely, impartial and effective resolution of internal and external disputes relating to corporate disclosures, stakeholder communication, regulatory engagement and governance matters. The Policy supports good corporate governance, legal and regulatory compliance, accountability and stakeholder confidence by ensuring that disputes are addressed fairly, transparently and with appropriate confidentiality.

Scope

The Policy applies to disclosure-related disputes involving the Group’s shareholders, directors, employees, regulators, investors, analysts, service providers, customers, media and the general public. It covers internal disputes, external disputes and cross-cutting matters that may affect the accuracy, completeness, timing or interpretation of the Group’s disclosures and communications.

Framework

1. Guiding Principles: The Policy is anchored on fairness, impartiality, confidentiality, compliance, accountability, timeliness and transparency.
2. Categories of Disputes: The Policy recognises internal, external and cross-cutting disputes arising from disclosure processes, regulatory engagement, shareholder concerns, investor communication, professional advisory matters, media interpretation or governance-related issues.
3. Internal Dispute Resolution: Internal disputes are addressed through a structured process beginning with informal resolution, followed where necessary by formal complaint submission, investigation, hearing, determination, closure and record-keeping.
4. External Dispute Resolution: External disputes are handled through formal receipt and acknowledgement, preliminary assessment, investigation or regulatory engagement, resolution and communication, escalation where necessary, documentation and protection from retaliation.
5. Escalation and Alternative Dispute Resolution: Where disputes remain unresolved after internal processes have been exhausted, the Policy provides for escalation to appropriate external mechanisms, including arbitration, mediation, expert determination or regulatory facilitation.
6. Documentation and Learning: Dispute records, outcomes, appeals, corrective actions and lessons learned are maintained to support accountability, auditability, governance reporting and strengthening of disclosure controls.

Roles & Responsibilities

Board of Directors: Provides overall governance oversight of the dispute resolution framework and ensures that material or high-risk disputes are addressed in a manner that protects the Group’s reputation, regulatory standing, disclosure integrity and stakeholder confidence.

Management: Receives, records, assesses and resolves disputes in line with approved procedures. Management coordinates investigations, engages relevant parties, prepares responses, supports regulatory interaction, escalates material or unresolved issues for executive review and implements corrective actions arising from dispute outcomes.

Why It Matters

• Provides a clear and fair mechanism for resolving disclosure-related disputes.
• Protects stakeholder confidence through transparent and accountable dispute handling.
• Supports regulatory compliance and reduces reputational, legal and governance risk.
• Ensures disputes are documented, escalated and resolved through appropriate channels.