ESR Funds Management (S) Limited (“ESR-FM”), the Manager of ESR-REIT, is committed to provide material information in a timely, accurate and transparent manner to the public, in accordance to the regulations of the Monetary Authority of Singapore, Singapore Exchange Securities Trading Limited (“SGX-ST”) and the Singapore Code of Corporate Governance 2018
2.1. The Investor Relations and Corporate Communications (“IRCC”) Policy establishes a framework of processes and practices to ensure proper communication and delivery of information to its stakeholders to make well-informed decisions.
2.2. ESR-FM will comply with all applicable securities regulations and ensure full and accurate disclosure of corporate communications materials. In addition to statutory disclosures, ESR-FM seeks to adopt a pro-active stance of voluntary disclosure of information deemed to have a potential impact on investment decisions by its stakeholders.
2.3. This policy is subject to regular reviews by the senior management team of ESR-FM to evaluate the efficacy of its communication channels in order to reflect current best practices and to keep its various stakeholders abreast of ESR-REIT’s business operations and financial performance.
ESR-FM adopts various communication avenues to convey its messages to all its stakeholders. ESR-FM is committed to disseminate all material information that would reasonably be required to make an informed decision about investment in ESR-REIT’s securities in a fair, timely and cost-efficient manner.
ESR-FM is committed to open and transparent communication with all stakeholders. ESR-FM promotes investor confidence by ensuring that trade in its securities takes place in an informed market.
ESR-FM is committed to communicate with stakeholders in a clear language that avoids unnecessary jargon and provides maximum understanding of its messages. The official communications language for ESR-FM is English. However, from time to time and depending on specific objectives some communication collaterals might be translated in other languages such as Chinese and Japanese.
For clarity, stakeholders are defined to include but not limited to the following:
(a) Investment Community
(b) General Community
ESR-REIT's spokespeople are the Chairman and the CEO. These spokespersons may designate other persons as spokespersons from time to time. All incoming investors, unitholders and media queries should be put through to a member of the IRCC team. From that point, the appropriate spokespersons will be identified to assist in handling the particular inquiry.
IRCC’s channels of communications and materials include but are not limited to the following:
(a) Reports and documents provided to SGX-ST and other regulators;
(b) Materials and statements in the annual reports, half-yearly financial results, interim quarterly business updates, press releases, letters and circulars to unitholders;
(c) Presentation materials;
(d) Statements released in response to news articles or publications concerning ESR-REIT;
(e) Correspondence and emails
(f) Verbal statements made to outside parties during meetings, briefings, press conferences, or during telephone conversations; interviews with the media;
(g) Speeches given on behalf of ESR-REIT; and
(h) Corporate Website (www.esr-reit.com.sg)
7.1.1. Interim quarterly business updates and half-yearly financial results will be issued to SGX-ST one day after approval by the Board has been obtained, outside the trading hours of SGX-ST. Copies of the business updates, financial results and all relevant accompanying materials will be posted on ESR-REIT's website as soon as practicable following their posting on SGX-ST.
7.1.2. ESR-FM holds a briefing with investors, analysts and media on a half-yearly and full-yearly basis, as soon as practicable following the release of the financial results on SGX-ST.
7.3.1. The AGM is held annually while the EGM is held only when the need arises according to the SGX Listing Manual.
7.3.2. Broadly, the content of the AGM will concentrate on the ESR-REIT's financial condition and performance, its strategy and outlook, and any relevant operational matters of interest to unitholders. Given the AGM is regarded as an important forum for investors to engage with the Board and senior management team, this event provides an opportunity for retail unitholders, especially, to gain a fuller understanding of ESR-REIT's operations and key strategic plans. As such, meetings will be conducted in a manner which permits reasonable enquiry. In line with ESR-FM’s commitment to equality of access to information, presentation materials from the AGM will be posted on ESR-REIT's website.
7.3.3. Matters which require unitholders’ consideration and approval are also clearly documented and detailed in the AR. Both the AR and Notice of general meeting are provided promptly to the unitholders within the stipulated timeline to ensure that sufficient time is given to the unitholders to review the documents.
7.3.4. Notices for general meetings are also published in the local newspaper, released via SGXNET and uploaded on ESR-REIT’s corporate website
7.3.5. ESR-REIT conducts voting by poll for all general meetings and the poll results are announced during the meeting. A separate announcement of the poll results will be made available via SGXNET after the conclusion of each meeting.
7.3.6. ESR-REIT publishes minutes of general meetings of unitholders on its corporate website as soon as practicable. The minutes record substantial and relevant comments or queries from shareholders relating to the agenda of the general meeting, and responses from the Board and Management.
As an on-going process, the IRCC team will survey its stakeholders especially the investment community from time to time to gauge external sentiments, either by way of formal meetings, or through seeking verbal opinion during occasions of contact with them. External opinion will be sought not only on operational and performance matters, but also on governance and strategic issues.
Recognising that factors affecting the unit price performance of ESR-REIT are often beyond management control and subject to market conditions, the IRCC team will nevertheless endeavour to address any enquiries of investor or unitholder received and formulate an appropriate response.
Upon receipt of complaint or feedback, the IRCC Team will:
(a) Assess the content / severity of the complaint based on the following criteria:
(b) Depending on the content / severity of the feedback, the IRCC team may escalate the issue to the senior management team. Where there is major financial or reputational impact to ESR-REIT, the Board must be notified of the complaint and be kept apprised of the status of the complaint.
(c) Assign appropriate team members or direct to the appropriate external vendors to provide response.
(d) Acknowledge complaint within 2 working days and provide update on the status of the feedback within 7 working days from acknowledgement date. All complaints should be resolved within 14 working days. If due to unforeseen circumstances that resolution cannot be completed within 14 working days, status update on the complaint should be provided to the investor / unitholder every 7 working days until completion of resolution.
(e) Summary of complaints should be tabled to the Audit, Risk Management and Compliance Committee and Board.
(f) Maintain records of all complaints and its handling / resolution (including those involving the external vendors).
(g) This process will also apply for complaints that are brought to the Financial Industry Disputes Resolution Centre. For any complaints concerning conduct issues of team members, IRCC will defer to the whistle-blowing policy.
138 Market Street
#26-03/04 CapitaGreen, Singapore 048946
Tel: (65) 6222 3339
Fax: (65) 6827 9339
Tel: (65) 6222 3339