(a)
in the period commencing one month before the public announcement of PLife REIT’s annual results and (where
applicable) property valuations and two weeks before the public announcement of PLife REIT’s quarterly results,
and ending on the date of announcement of the relevant results or as the case may be, property valuations; and
(b)
at any time while in possession of unpublished price sensitive information.
The directors and employees of the Manager have been directed to refrain from dealing in units on short term considerations.
In addition, the Manager has undertaken that it will not deal in the units during the period commencing one month before
the public announcement of PLife REIT’s annual results and (where applicable) property valuations and two weeks before
the public announcement of PLife REIT’s quarterly results, and ending on the date of announcement of the relevant results
or as the case may be, property valuations.
Further, the Section 137ZC of the SFA (
relating to notification of unitholdings by responsible persons
) requires the Manager to,
inter alia, announce via SGXNET the particulars of any acquisition or disposal of interest in PLife REIT’s units by the Manager
no later than the end of the business day following the day on which the Manager became aware of the acquisition or disposal.
RISK ASSESMENT AND MANAGEMENT OF BUSINESS RISK
Effective risk management is a fundamental part of PLife REIT’s business operations. Recognising and managing risk is central
to the business and protecting Unitholders’ interests and value. PLife REIT operates within overall guidelines and specific
parameters set by the Board. Each transaction is comprehensively analysed to understand the risk involved. Responsibility
for managing risk lies initially with the business unit concerned, working within the overall strategy outlined by the Board.
The Board meets quarterly (or more often, if necessary) and will review the financial performance of the Manager and PLife
REIT against a previously approved budget. The Board will also review the business risks of PLife REIT, examine liability
management and will act upon any comments from the auditors of PLife REIT.
As a result of the licensing regime for managers of REITs under the SFA, the Manager, as a holder of a CMS Licence, has
established internal procedures to ensure compliance with the relevant laws, regulations and guidelines relating to anti-
money laundering and countering the financing of terrorism and has also adopted procedures to ensure that all material
outsourcing comply with the MAS Guidelines on Outsourcing issued in October 2004 and last updated on 1 July 2005.
The Manager has appointed experienced and well-qualified management personnel to handle the day-to-day operations
of the Manager and PLife REIT. In assessing business risks, the Board will consider the economic environment and risks
relevant to the property and healthcare industry. It reviews management reports and feasibility studies on investment risks
prior to approving all investment decisions. The management meets regularly to review the operations of the Manager and
discuss any disclosure issues.
WHISTLE-BLOWER PROTECTION POLICY
The Manager has established a whistle-blower policy which reflects the Manager’s commitment to conduct its business
within a framework that fosters the highest ethical and legal standards. In line with this commitment and PLife REIT’s
commitment to open communications, the whistle-blower policy aims to provide an avenue for employees to raise concerns
and reassurance that they will be protected from reprisals or victimisation for whistle-blowing in good faith. The Audit
Committee reviewed the whistle-blower policy which provides for mechanisms by which employees may, in confidence,
raise their concerns about possible improprieties in financial reporting or other matters and was satisfied that arrangements
are in place for the independent investigation of such matters and for appropriate follow-up action. The Chairman of the
Audit Committee is the first contact for issues raised under this policy.
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PA R K WAY L I F E R E I T
CORPORATE
GOVERNANCE
