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Whistle Blowing Policy

The Manager adopts a zero-tolerance stance against any form of illegal activity, including corruption, bribery and other impropriety involving its employees and associates, and will take all necessary steps to eradicate such conduct if discovered. Accordingly, a whistle blowing policy (the “Whistle Blowing Policy”) has been put in place to provide a channel through which employees, being a director, executive, manager or other officer or contractor of the Manager (each, a “Whistleblower”) may report in good faith and in confidence any reportable conduct, which in the view of the Whistleblower, is:

  1. dishonest;
  2. a fraudulent misappropriation of assets;
  3. corrupt;
  4. illegal or a breach of any applicable laws (including theft, drug sale/use, violence or threatened violence and criminal damage against property);
  5. unethical (either representing a breach of the Manager’s code of conduct or generally);
  6. other serious improper conduct or gross mismanagement;
  7. an unsafe work-practice; or
  8. any other conduct which may cause financial or non-financial loss to the Manager or be otherwise detrimental to the interests of the Manager,

and arrangements are in place for independent investigation with appropriate follow-up action. Under the Whistle Blowing Policy, the Manager ensures that the identity of the Whistleblower is kept confidential and anonymous reporting is allowed. The Manager remains committed to protecting the Whistleblower against detrimental or unfair treatment. All employees can notify in writing of any reportable conduct to the Whistleblower protection officer (the “Whistleblower Protection Officer”) or the Chairperson of the ARCC. The email address of the Whistleblower Protection Officer is compliance@aimsapac.com, and the Whistle Blowing Policy is available on AA REIT’s website at https://www.aimsapacreit.com/whistle-blowing.html.

The ARCC is designated as the indepenfdent unction to investigate all whistleblowing reports and is responsible for oversight and monitoring of whistleblowing. The ARCC reviewed the Whistle Blowing Policy and is satisfied that reportable conduct may be raised in confidence and that arrangements are in place for the independent investigation of such matters and for appropriate follow-up action.

In FY2026, the Whistleblower Protection Officer or the Chairperson of the ARCC did not receive any report of reportable conduct.


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