Cromwell European REIT - Annual Report 2021

The whistle-blowing policy and procedures are reviewed by the ARC from time to time to ensure that they remain current. No whistle-blowing reports were recorded in FY 2021. Anti-Money Laundering and Countering the Financing of Terrorism Measures As a holder of a capital markets services licence issued by MAS, the Manager abides by the MAS’ notices and guidelines on the prevention of money laundering and countering the financing of terrorism. Under these guidelines, the main obligations of the Manager are: (a) evaluation of risk; (b) customer due diligence; (c) suspicious transaction reporting; (d) record keeping; (e) employee screening and representative screening; and (f) training. The Manager has developed and implemented a policy on the prevention of money laundering and terrorist financing and is alert at all times to suspicious transactions. Where there is a suspicion of money laundering or terrorist financing, the Manager performs due diligence checks on its counterparties in order to ensure that it does not enter into business transactions with terrorist suspects or other high-risk persons or entities. Suspicious transactions are also reported to the Suspicious Transaction Reporting Office of the Commercial Affairs Department. The Manager routinely screens its counterparties through the World-Check One screening platform, which screens against sanctions lists published by, including, but not limited to, the Financial Action Task Force (“FATF”), the United Nations, Office of Foreign Asset Control (“OFAC”) of the United States Department of Treasury, Office of Financial Sanctions Implementation (“OFSI”) (UK) and the European Union. This include the latest sanction lists issued in relation to the recent Russian invasion of Ukraine. Under this policy, the Manager must retain all relevant records or documents relating to business relations with its customers or transactions entered into for a period of at least five years following the termination of such business relations or the completion of such transactions. All prospective representatives of the Manager are screened against various lists of terrorist suspects issued by MAS. Periodic training is provided by the Manager to its Directors, employees and representatives to ensure that they are updated and aware of applicable anti-money laundering and terrorist financing regulations, the prevailing techniques and trends in money laundering and terrorist financing and the measures adopted by the Manager to combat money laundering and terrorist financing. CORPORATE GOVERNANCE FOCUS ON STRENGTHS PIVOT TO LOGISTICS 184