(SGX:584)
REG: 198403368H

Introduction

Led by AJJ Medtech's company ethos of "Fairness, Transparency, Professionalism, Integrity", we have earned the trust of our customers, shareholders, communities, and regulators by demonstrating the highest level of integrity. We are committed to cultivating a corporate culture that emphasizes absolute compliance with Singapore laws and ethical business conduct. We adhere to a zero-tolerance policy and will not tolerate any form of non-compliance, bribery, and corruption. AJJ Medtech has a comprehensive Compliance Program and must comply with the requirements of the Health Sciences Authority of Singapore, and the code of conduct applicable to the medical devices and medical equipment industry. Our Compliance Program is custom-tailored and includes a comprehensive compliance control framework that applies to the entire company. This Compliance Program demonstrates our commitment to the highest standards of corporate conduct and integrity. The following is an overview of the essential elements of our Compliance Program.

 

I. Compliance Organization

AJJ Medtech Holdings LimitedSGX. 584 Co.Reg.No:198403368H 8 Commonwealth Lane, #02-04 Singapore 149555 Tel: 6235 5091 E-mail:general@ajjmedtech.com.sgrules and regulations of the Singapore Exchange (SGX) (including SGX Listing Manual, SGXthe compliance Rules, SGX Regulatory Manual, SGX Trading Rules, SGX Announcements and Notices), “Prevention of Corruption Act” and “the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act”, in compliance withAJJ Medtech's Compliance Program reflects our comprehensive commitment to complying with Singapore law and includes elements specifically designed to comply with Singapore law. AJJMedtech's Compliance Committee is led by the CEO, with the company’s key management team as its members. The Compliance Committee is responsible for developing, executing and overseeing the Compliance Program and the leading management in the governance efforts to manage the Compliance Program. Each Director of AJJ Medtech has the appropriate authority to exercise independent judgment and has direct access to the company's board leadership and joint efforts to implement AJJ Medtech's Compliance Program. Every employee of the company is entitled to report directly to the Chairman of the Audit Committee (AC Chairman) and to engage in ongoing communications with him or her. As business and industry conditions change, the Compliance Committee reviews and updates AJJ Medtech's policies and procedures. The Compliance Committee has the authority to propose and implement necessary changes within the company.

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II. Policies and Procedures

Our compliance strategy encompasses a detailed set of policies and procedures, including the company's code of conduct, incorporating the mission "All for the commitment to life". These policies detail the requirements for compliance with Singapore's laws and regulations. We also conduct annual verification to ensure compliance with AdvaMed's Code of Ethical Interactions with Healthcare Professionals. In addition, under Singapore regulations, AJJ Medtech establishes an annual aggregate limit on items of value and activities provided to healthcare professionals, which can be adjusted on a case-by-case basis.

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This approach ensures that AJJ Medtech maintains high standards of ethics and compliance in its interactions with healthcare professionals, while complying with Singapore’s medical device regulatory requirements as stipulated in the Health Products Act and the Medical Devices Regulations.

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III. Effective training and education

At AJJ Medtech, educating and training employees on their legal and ethical responsibilities under Singapore’s laws, regulations, and Company policies constitutes a key component of our Compliance Program. This training involves all relevant employees and includes compulsory courses on Singapore’s healthcare-related laws and our policies and procedures. This training program is designed to deepen employees' understanding of compliance policies and often includes test questions to assess employees' mastery of these policies and concepts. We also regularly review and update our training programs to explore new training opportunities and ensure that these programs continue to meet the company's compliance standards.

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IV. Effective communication channels

One of the distinguishing features of AJJ Medtech's Compliance Program is a strong commitment to a vibrant, well-known, and effective open reporting environment. Employees are AJJ Medtech's first and best line of defense in early identification of potential compliance issues. We strive to establish and maintain open lines of communication between the Board of Directors, the Management, and all employees. We encourage employees, agents, and vendors with whom we do business to report any possible misconduct, potential conflicts, or known violations of company policies and/or procedures to their supervisor, manager, or the Board of Directors. Employees can contact the Board of Directors directly via email, mail, phone, or in- person meeting.

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In addition, AJJ Medtech has established a system to receive complaints or enable employees to get information or advice regarding issues directly to our Legal and Compliance team leader Mr. Leu Yongren (leuyongren@ajjmedtech.com.sg). Complaints and inquiries can be made anonymously. We also encourage employees, officers and agents to raise questions about any possible violations or unclear activities related to our Compliance Program, which can be raised through any established communications channel. AJJ Medtech has also implemented measures to protect the anonymity of those who raise potential concerns and to protect whistleblowers from retaliation. AJJ Medtech will not tolerate retaliation or discipline for reporting

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V. Monitoring and Auditing

AJJ Medtech's Compliance Committee are responsible for developing an audit program that monitors the Company's compliance with compliance policies. Through these audits, the Management team is able to identify potential or existing concerns and possible program improvements, which include implementing corrective actions as needed, working to prevent recurrence of violations. The type, scope and frequency of these audits and reviews are determined by a variety of factors, including new regulatory requirements, changes in company practices and other relevant factors.

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VI. Enforcement through widely known disciplinary codes

AJJ Medtech's code of conduct clearly states to all employees, including management and agents, that violations of company policies and laws will result in disciplinary action, up to and including termination of employment. It ensures that every employee understands their responsibilities and consequences under Singapore's legal framework, emphasizing the company's strong commitment to compliance and ethical conduct.

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VII. Investigate and respond to potential violations and implement corrective action initiatives

AJJ Medtech’s Compliance Committee conducts thorough investigations of all reported violations and/or allegations, as well as cases of suspected misconduct.

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In addition, the Compliance Committee is responsible for ensuring that corrective actions taken in response to violations are implemented, which may include retraining employees, increasing supervision, and imposing disciplinary sanctions. This process demonstrates the company's commitment to maintaining strict compliance standards.

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AJJ Medtech 's Annual Compliance Statement complies with the relevant provisions of the Health Products Act .

AJJ Medtech's compliance statement has complied with the provisions of Singapore's Health Products Act and its Health Products (Medical Devices) Regulations 2010. In accordance with these regulations, AJJ Medtech's Compliance Program includes annual limits on items and services for each employee in Singapore. We are committed to maintaining its Compliance Program to ensure that it meets or exceeds the requirements of Singapore law in all key areas.

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This statement applies only to AJJ Medtech's business activities in Singapore.

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Transparency Report

AJJ Medtech is a Singapore-based medical technology and services provider that maintains a robust Compliance Program. The company partners with healthcare professionals and institutions in research, product development and clinical testing, ensures the safe and effective use of medical technology through comprehensive training programs and provides ongoing support and technical maintenance.

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In Singapore, transparency reporting requirements for medical device manufacturers are administered by the Health Sciences Authority (HSA). Under the Health Products Act and Medical Device Regulations, manufacturers must perform strict post-market surveillance and report any adverse events (AEs). These adverse events, including those that pose a serious threat to public health, result in death, and serious deterioration of health, must be reported within a specified time. For example, adverse events that pose a serious threat to public health must be reported within 48 hours, while events resulting in death or serious deterioration of health must be reported within 10 days.

For any specific Singapore compliance or reporting issues, A JJ Medtech, like all other medical device companies operating in this jurisdiction, will comply with these regulations to ensure the effectiveness of its medical products and the safety of end users.

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Anti-corruption

For AJJ Medtech, critical to its business success is its reputation for integrity. AJJ Medtech has earned the trust of its customers, shareholders, communities and regulators by demonstrating integrity. The company is committed to cultivating a corporate culture that emphasizes compliance with Singapore laws and ethical business conduct.

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AJJ Medtech adheres to a zero-tolerance policy and will not tolerate bribery and corruption in any form. Accordingly, its global anti-corruption policy expressly prohibits offering or accepting any form of transfer of value, including but not limited to gifts, entertainment, travel or employment opportunities, to any person or group for corrupt purposes. The policy also prohibits so-called "convenience payments" to expedite a government official's routine work.

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AJJ Medtech’s anti-corruption compliance measures include:

• Compliance Review and Approval: Before any item or service of value is provided to a government official, a compliance review and approval must be obtained. This ensures that all forms of gifts and business entertainment comply with the relevant legal thresholds.

• Accurate Record Keeping: AJJ Medtech insists on maintaining the accuracy of accounts, records and books relating to the Company’s business, which includes all transactions with customers, suppliers and other business partners.

• Due Diligence and Supervision: Conduct rigorous due diligence and ongoing supervision of intermediaries, agents, joint venture partners and other related entities to ensure that they comply with the company's high standards and policies.

• Reporting and Anti-Retaliation Policy: AJJ Medtech encourages employees to report potential corruption matters, such as through the Company’s whistleblower email at whistleblower@ajjmedtech.com.sg, and strictly prohibits any form of retaliation against whistleblowers in good faith.

• Training to prevent improper payments: Provide comprehensive training to all employees to increase their awareness and understanding of preventing improper payments.

• internal control and accounting process: Strengthen internal control and audit process to ensure timely detection and prevention of any possible improper payment behavior and maintain the accuracy of all transaction records.

• Special attention to risk areas: Special attention is paid to high-risk areas that may involve bribery and corruption risks, such as gifts, entertainment, travel and living allowances.

• Due Diligence for Mergers, Acquisitions and Joint Ventures: Before undertaking any mergers, acquisitions or joint ventures, enhance due diligence on related risks to ensure that all business activities comply with the company’s compliance standards.

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In Singapore, anti-corruption regulations are primarily governed by the Prevention of Corruption Act, which sets out the legal consequences of bribery by public officials and in the private sector. In addition, companies in Singapore are also subject to strict legal requirements and must implement effective compliance measures to prevent corrupt practices. AJJ Medtech follows these regulations to ensure integrity and transparency in its global operations. This strong compliance culture is critical to a company's long-term success and reputation.