Corporate Governance at True - True Sustainability

True is committed to conducting our business in a credible, responsible, transparent, and auditable manner, emphasizing sustainability. The Board of Directors upholds governance principles within the framework of Good Corporate Governance, emphasizing ethical practices and fair treatment of stakeholders.

Corporate governance systems ensure that a company is managed in the interests of shareholders, including minority shareholders. On the one hand this includes checks and balances that enable the Board of Directors to have appropriate control and oversight responsibilities. On the other hand, Executive Management incentives must be set in such a way that management interests are aligned with shareholders’ interests.

True CODE OF CONDUCT

In the fast-paced business landscape, integrity acts as our north star, guiding us through the toughest decisions and ensuring that honesty and trust remain the foundation of our culture. True believes that the level of honesty and integrity within an organization is a clear indicator of sustainable growth. True has the Code of Conduct in conducting business, guiding our employees to operate responsibly and in compliance with organizational goals, policies, and the requirements of laws, regulations, and standards, both nationally and internationally.

ANTI-CORRUPTION MANAGEMENT

True is committed to combating corruption in all its forms. The Company’s Code of Conduct and Anti–Corruption Policy has been developed and disclosed on the Company’s website. True requires employees to engage with the Company in order to become a corruption-free organization as embodied in TRUE’s core value C-CREDIBLITY by constantly adhering to and supporting the anti-corruption policy.

The Company has Zero Tolerance for Corruption and is committed to working against Corruption in all forms, maintaining the highest possible ethical standards and complying with all applicable anti-corruption laws.

INTEGRITY HOTLINE

The Integrity Hotline is a confidential channel, with an option for anonymous reporting, to ask questions and raise concerns about possible breaches of True corporation PCL’s Code of Conduct, including relevant laws, regulations and Governing Documents.

The Investigation Team, under the supervision of the Head of the Internal Audit & Investigation Division, is responsible for managing reported cases in line with our Whistleblower and Investigation Policy. This includes a comprehensive process for addressing concerns, which involves fact-finding, investigation, and assessment, as well as implementing effective corrective actions and, where appropriate, disciplinary measures.

The four steps of the fact-finding process include:

1. Risk Assessment: This initial stage involves verifying the information received to prevent false reporting or any attempts to misuse the integrity hotline for sabotage.

2. Categorization: Once the investigation team confirms the credibility of the whistleblower’s information, the concerns reported through the hotline are categorized in accordance with the company’s policy. This categorization assists in identifying appropriate solutions and engaging domain experts as needed, specific to the risk category.

3. Fact-Finding: A dedicated fact-finding committee is formed, also comprising individuals directly involved in the issue, who actively participate in the fact-finding process while upholding their independence. In certain instances, the involvement of credible and independent external experts is sought to enhance transparency and prevent any potential conflicts of interest.

4. Report Filing: After the case has been thoroughly reviewed and investigated, the committee will submit a report to the Disciplinary Action Committee (DAC) in order to identify appropriate measures for improving work processes as well as proposing disciplinary actions if the case entails violations of the company’s policy.

The Integrity Hotline is operated by an independent third-party service provider. Any query or report you make will be treated confidentially and respectfully. The service is accessible online and available 24 hours a day, 7 days a week. We consistently provide training and communication to our employees, suppliers, and other stakeholders, encouraging them to speak up through the hotline.

Complaints submitted through the Integrity Hotline will be handled thoroughly, with appropriate measures taken to address concerns. Retaliation against whistleblowers is strictly prohibited, and the Company will not tolerate any form of retaliation.

Tax Governance

True has a group-wide Finance Policy that incorporate taxation strategy to address tax and reputational risks in a clear and sustainable way. Please refer to our Finance policy.

RISK AND CRISIS MANAGEMENT

Effective risk and crisis management is vital for long-term financial planning and organizational flexibility. True is committed to implementing effective risk management practices, encompassing the promotion of a culture, processes, and structures that enable the identification, assessment, and management of both opportunities and potential impacts.