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TOTM TECHNOLOGIES LIMITED Environmental & Social Information 2025

Sep 26, 2025

67406_rns_2025-09-26_c9faa1e9-00c3-473f-9ee2-688254db0ef5.pdf

Environmental & Social Information

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Table of Contents
BOARD STATEMENT 3
COPORATE PROFILE 5
SUSTAINABILITY APPROACH 5
ECONOMIC 8
ENVIROMENTAL 9
SOCIAL 10
GOVERNANCE 15
CLIMATE-RELATED DISCLOSURES 18
GRI CONTENT INDEX 20

This sustainability report has been reviewed by the Company’s sponsor, UOB Kay Hian Private Limited (the “ Sponsor ”). This sustainability report has not been examined or approved by the Singapore Exchange Securities Trading Limited (the “ SGXST ”) and the SGX-ST assumes no responsibility for the contents of this sustainability report, including the correctness of any of the statements or opinions made or reports contained this sustainability report.

The contact person for the Sponsor is Mr. Lance Tan, Senior Vice President, at 83 Clemenceau Avenue, #10-01 UE Square, Singapore 239920, telephone (65) 6590 6881.

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BOARD STATEMENT

We are pleased to present the Sustainability Report (“ Report ”) of TOTM Technologies Limited (“ TOTM Technologies ”, or the “ Company ” and together with its subsidiaries, the “ Group ”) for the financial year ended 31 May 2025 (“ FY2025 ”). The Group’s sustainability report summarises the expectations from various stakeholders, the general business environment that the Group is operating in and what the Group has done in order to ensure the sustainability of the Group over the years.

Reporting Scope and Framework

This Report is prepared in compliance with the Rules 711A and 711B of the Listing Manual Section B: Rules of Catalist of the SGX-ST (“ Catalist Rules ”) and is referenced to the guidance set out in Practice Note 7F of the Catalist Rules. It is also prepared with reference to the Global Reporting Initiative (“ GRI ”) Standards 2021. We have chosen to report using GRI Standards because it is an internationally recognised reporting framework that covers a comprehensive range of sustainability disclosures. It provides the Group with a flexible and future-proof reporting structure as the approach advocated by GRI ensures its processes and topics are always up-to-date and relevant.

This Report highlights the key economic, environmental, social and governance (“ EESG ”) related initiatives carried out throughout the 12-month period, from 1 June 2024 to 31 May 2025 (“ Reporting Period ”). The Report covers all entities within our organisation to fully understand our sustainability efforts.

The Group recognises that the importance of preparing climate-related disclosures aligned with the Task Force on Climate-related Financial Disclosures (“ TCFD ”) recommendations as prescribed by the Singapore Exchange in Practice Note 7F. Although the Group has yet to embark on our journey with the TCFD-aligned disclosures due to limited resources, we are committed to progressively implementing the framework in the coming years. The Group will continue to monitor any emerging climate-related risks and/or opportunities relating to its supply chain and operations regularly. We will consider the climate-related disclosure requirements based on TCFD recommendations in our subsequent Sustainability Report. For more details about our climate-related reporting, please refer to pages 18 to 19.

Sustainability Governance

The Board of Directors (the “ Board ” or “ Directors ”) oversees the management and monitoring of the material EESG factors affecting the Group and considers them in the determination of the Group’s strategic direction and policies while the key management team are responsible for the implementation of sustainability initiatives. In the purpose of carrying out sustainability management duties, the Board has attended a comprehensive sustainability training course recommended by SGX-ST. This training is aligned with our commitment to incorporating sustainable practices into our business operations.

Our senior management team, including our Executive Director, Chief Financial and Strategy Officer and Deputy Chief Financial Officer, leads our sustainability efforts. They ensure that our business objectives align with our commitments to sustainable development. The senior management team maintain ongoing communication with the Board to inform them of our progress toward achieving our sustainability goals.

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Sustainability is a part of the Group’s wider strategy to create long-term value for all its stakeholders. As such, the key material EESG factors for the Group have been identified by management. An independent third party has not verified the data and information provided. We have relied on internal data monitoring and verification to ensure the accuracy of the data and information provided.

We have subjected our sustainability reporting process to an internal review, pursuant to Rule 711B (3) of the Catalist Rules. The internal review has been conducted in accordance with the International Standards for the Professional Practice of Internal Auditing issued by the Institute of Internal Auditors. Where required and as the Group’s sustainability reporting matures, the Group will consider seeking external independent assurance for its sustainability report.

We welcome feedback from our stakeholders concerning our sustainability efforts, enabling us to improve our policies, systems, and results consistently. Please send your comments and suggestions to [email protected].

On behalf of Board of Directors,

Mr. Pierre Prunier Executive Director

26 September 2025

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CORPORATE PROFILE

TOTM Technologies provides end-to-end identity management and biometrics products, powering Digital Identity and Digital Onboarding solutions. The Group’s multi-modal range of technologies includes internally developed technologies as well as technology licensed from strategic partners such as National Institute of Standards and Technology (“ NIST ”)-rated core biometrics matching software that is proven in ultra large-scale identity deployments. The Group’s in-house expertise comprises innovators, disruptors and technologists providing the full technology suite in biometrics such as multi-modal technologies (face, finger, iris), eKYC, real-time liveness detection, age classification and patented cryptograph that stores data encrypted with biometrics.

The Company has successfully executed its asset-light pivot strategy with a major emphasis on digital products and solutions, while achieving significant milestones in cost rationalisation. TOTM Technologies’s core mission remains unchanged: to deliver trusted digital identity, biometric and digital transformation solutions that address critical needs in government, public safety, law enforcement, and commercial sectors across Southeast Asia and beyond. Our strategic positioning as a Digital Identity and Biometrics Integrator (“ DIBI ”) continues to strengthen, supported by our firstmover advantage in Indonesia’s identity management sector. As of July 2025, the Group manages one of the world’s largest 3-modal identity management platforms, with over 223 million eligible Indonesian citizens enrolled on the KTP-el (Indonesia’s National Identity) platform. This scale and technology sophistication, combined with our proven track record and regulatory compliance, positions TOTM Technologies for sustained growth in the expanding digital identity market.

SUSTAINABILITY APPROACH

OUR SUSTAINABILITY METHODOLOGY

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Engage Assess
Plan and Scope Collect Data Report
Stakeholders Materiality
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STAKEHOLDERS ENGAGEMENT

An important starting point in our sustainability journey is to identify our stakeholders and material aspects relevant to our business. The interests and requirements of key stakeholders are also taken into account when formulating corporate strategies. These key stakeholders include, but are not limited to, customers, suppliers, shareholders, employees, and regulators. We adopt both formal and informal channels of communication to understand the needs of key stakeholders and incorporate these into our corporate strategies to achieve mutually beneficial relationships.

Stakeholders Engagement
Platforms
Frequency Key Concerns Raised
Vendor assessment Annually Joint development
Suppliers Emails/Calls
Face-to-face meetings
Continuously
Continuously

Contracts fulflment
Fair and transparent
procurement
Shareholders Annual General
Meeting/Extraordinary
General Meeting
Annual Report
Annually
and
when required
Annually

Ensure compliance with
SGX rules and
regulations
Realise healthy growth
Announcement Continuously Timely and adequate
Corporate Website Continuously disclosures and updates
Customers Face-to-face meetings
and virtual meetings
Email feedback
Continuously
Continuously

Quality service
Rights protection
Customer cold calls Continuously
Staff appraisal Continuously
Employees Whistleblowing policy
updates
Department &
Management Meetings
Staff engagement
sessions
Annually
Continuously
Continuously

Guarantee of basic
rights and interest
Employee capabilities
and career development
Board Board meetings Half yearly and
when required
Financial sustainability
and business viability of
operations
Board circulation via e-
mails
Continuously Regular updates on
operational activities
Authorities/ Regular reports Continuously Strengthen safety
management
Regulators Websites Continuously Compliance with
Calls Continuously regulations

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MATERIALITY ASSESSMENT

Our sustainability reporting process begins with the identification of relevant EESG factors. In order to determine if a factor is material, we assessed its potential impact on the economy, environment and society and its influence on the stakeholders. When a factor is deemed to be material, it will be prioritised for further review. Processes are as shown below:

Identification Prioritisation Validation Review

Subject to validation by the Board, the result of this process is a list of material factors disclosed in the Sustainability Report. Applying the guidance from GRI, the following are our material EESG factors:

ECONOMIC
Economic Performance
Anti-corruption
ENVIRONMENTAL
Supplier Environmental Assessment
SOCIAL
Diversity and Equal Opportunity
Occupational Health and Safety
GOVERNANCE
Corporate Governance
Business Ethics and Compliance
Enterprise Risk Management
Environmental Compliance

SUSTAINABILITY COMMITMENTS

As part of our commitment to sustainable development, the Group has enhanced our disclosures and reported sustainability performance targets set for the short-term (by FY2025), medium-term (by FY2030), and long-term (by FY2050). By tracking our progress, we can identify areas for improvement and ensure that our sustainability efforts are aligned with our overall business strategy. For details on the Group’s achievement of its short-term targets, refer to pages 9 to 18 of the report.

Material
EESG
Factors
Short-term Targets Medium-term
Targets
Long-term Targets
Economic
Performance
For FY2025, the Group reported a lower negative EBITDA of $1.8 million,
compared to $4.5 million in fnancial year ended 31 May 2024
(“FY2024”). We are committed to turning this around and improving the
Group’s EBITDA profitability going forward.
Anti-corruption We target to achieve
zero
incidents
of
corruption that leads to
disciplinary
actions,
termination
of
contracts and legal
disputes
brought
against the Group.
We are committed to upholding high standards
of conduct and ethical behaviour in all our
business activities, supporting a culture of
compliance and good corporate governance,
and striving for zero reported incidents of
corruption.

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Supplier
Environmental
Assessment
We aim to ensure that all new major suppliers will be assessed against
environmental responsibility performance and compliance with relevant
laws and regulations.
We aim to ensure that all new major suppliers will be assessed against
environmental responsibility performance and compliance with relevant
laws and regulations.
Diversity and Equal
Opportunity
We aspire to engage our employees through an array of team-building
and motivational initiatives and maintain the diversity in our workplace in
terms of gender, nationality, and age group mix – to strengthen our
competency while providing fair and equal employment opportunities for
all in the short-, medium- and long-term. We also strive to maintain zero
incidents of unlawful discrimination against employees.
Occupational
Health
and Safety
We will continuously
work
towards
maintaining
zero
occurrence
of
workplace fatality and
non-fatal
workplace
injuries.
We aim to continue ensuring that we provide
healthy and safe working conditions and target
to achieving zero major incident1of health and
safety and zero fatalities in the workplace.
Corporate
Governance
We strive to continuously adhere to the Code of Corporate Governance.
Business Ethics and
Compliance
We will continue to maintain and ensure no signifcant fnes2or non-
monetary sanctions for non-compliance with laws and regulations.
Enterprise
Risk
Management
We strive to identify, manage, and respond timely to any gaps in
sustainability reporting regulatory compliance.
Environmental
Compliance
We strive to continue being in full compliance with laws, environmental
rules and regulations as to not result in significant fines or sanctions.

ECONOMIC

ECONOMIC PERFORMANCE

In terms of direct economic value generated, distributed and retained, please refer to the following sections in our Annual Report:

  • Letter to Shareholders, pages 2 to 6;

  • Financial Highlights, pages 8 to 9;

  • Financial Review, pages 10 to 11; and

  • Financial Statements, pages 61 to 138.

1 Major incidences of health and safety are those related to life-threatening injuries or those requiring extended hospitalisation or medical treatment.

2 Significant instances of non-compliance with laws and regulations are those that would result in significant fines above S$10,000 and/or non-monetary sanctions which include restrictions imposed by governments, regulatory authorities, or public agencies on the Group’s activities or operations.

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ANTI-CORRUPTION

We do not tolerate corruption in any form and strive to conduct our business with utmost integrity and transparency. This has been made clear to all Group’s Directors, officers and employees. The Directors and senior management team have attended the relevant trainings provided by Singapore Institute of Directors which inculcated business ethics and integrity. Our whistleblowing email was set up so that anyone who wants to report any issue on corruption can do so confidentially. Any report of corruption will be escalated to the attention of the Audit Committee (“ AC ”).

As of now, the Group does not have any formal anti-corruption policies in place. However, the Group is actively working towards formulating a comprehensive anti-corruption policy in FY2026, which will be clearly communicated across all levels of the organisation as well as relevant stakeholders. The new policy will serve as a formal commitment to uphold the highest standards of integrity and ethical conduct, ensuring that the Group operates in full compliance with anti-corruption regulations and industry’s best practices.

WHISTLEBLOWING POLICY

The Group has implemented a whistleblowing policy. The policy aims to provide an avenue for employees and external parties to raise concerns about misconduct or improprieties in the Group and at the same time assure them that they will be protected from any prejudicial implications for whistleblowing in good faith and the identity of whistleblower is kept confidential. Significant cases are reviewed by the AC for adequacy of investigation actions and resolutions. The Company has provided the email address [email protected] which is accessible by the members of AC on the Company’s website to allow external parties to raise any concerns they may have.

Similar to FY2024, there were no reported incidents of corruption in FY2025. There was reported incident of whistleblowing and the management has responded immediately to address the issues and the incident has been addressed and resolved. No employees were dismissed or disciplined for corruption, nor did the Group face any contract termination or non-renewal due to violations related to corruption. There were also zero incidents of public legal cases regarding corruption brought against the Group and its employees.

The Group met its short-term target, with zero incidents of corruption resulting in disciplinary action, contract termination, or legal disputes.

ENVIRONMENTAL

TOTM Technologies endeavors to minimise the potential impact of our operations on the environment. We are committed to reducing any environmental footprint and consumption of natural resources in all possible aspects of business operations. We encourage the use of renewable materials and resources, and where possible, reduce waste through reusing and recycling. We avoid any unnecessary use of hazardous materials and products and take all reasonable steps to protect the environment when such materials must be used, stored or disposed of.

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SUPPLIER ENVIRONMENTAL ASSESSMENT

TOTM Technologies will continue to reduce its environmental impact and encourage its stakeholders, including suppliers and trading partners, to meet the same expectations. We will assess suppliers' environmental responsibility performance and compliance with relevant laws and regulations and engage them to determine EESG focus areas on the pursuit of co-creating sustainable value.

We aspire to continuously promote and integrate sustainability in our business operations and consider stakeholders' interests. Environmental performance is being considered as our sustainability reporting process matures. We pledge to uphold sustainable business practices across our value chain, from subsidiaries to suppliers, and trust that sustainable supply chain management drives organisational excellence to deliver desirable business results to the stakeholders.

Over the course of FY2025, the Group did not engage any new major suppliers that would require conducting our supplier environmental assessment. Supplier assessment is a critical process designed to ensure that any new suppliers meet our stringent environmental and quality standards, especially since our customers are predominantly from the government sector, where adherence to high compliance and operational standards is paramount.

As part of our ongoing commitment to maintaining good procurement standards and practices, the Group evaluates equipment and materials suppliers to ensure that they align with our specific requirements and adhere to the protocols expected. Moreover, it confirms that suppliers are providing stable and reliable materials, thereby contributing to the reduction of procurement risks. Through these measures, the Group aims to safeguard the integrity and quality of its supply chain, continuously enhancing its capacity to meet customer expectations and regulatory obligations.

In FY2025, no assessments were carried out as the Group did not engage any new major suppliers (FY2024: Nil), thereby achieving its short-term target of assessing all new major suppliers on environmental responsibility and compliance with applicable laws and regulations.

SOCIAL

Our employees are our greatest assets. Their contributions and support are always valued. As such, we conduct regular reviews of compensation and benefits policies according to the industry benchmark, financial results as well as individual performance of employees. Furthermore, the Group places great emphasis on the training and development of employees and regards excellent employees as a key factor in remaining competitive.

We respect human rights and support the elimination of all forms of forced and compulsory labour, especially child labour. The Group does not tolerate any discrimination in respect of employment and occupation. We are committed to embedding human rights principles to ensure that our operations are devoid of any negative human rights impact.

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DIVERSITY AND EQUAL OPPORTUNITY

Board Diversity

We take pride in fostering a diverse and inclusive Board. We firmly believe that a Board comprising members with varied backgrounds, experiences, and perspectives is essential to our Company’s growth and success as we can timely and strategically response to the market shifts and changing customers’ demands.

Our Board diversity policy is designed to ensure that the Board’s composition reflects a wide range of skills, expertise, and viewpoints. We continuously assess our Board’s composition and actively seek qualified individuals who can bring unique insights and contribute to a more inclusive decisionmaking process.

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Board Gender Diversity
100% 100%
0% 0%
FY2025 FY2024
Male Female
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Board Age Diversity
75%
58%
42%
25%
0% 0%
FY2025 FY2024
< 30 years old 30-50 years old > 50 years old
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All Board appointments are made based on merit, in the context of the skills, experience, independence and knowledge which the Board as a whole requires to be effective. For more detailed information about our Board Diversity, please refer to our Corporate Governance Report in the Annual Report, pages 24 to 25.

Employee Diversity

A diverse workforce is an asset in today's ever-changing global marketplace. We cultivate an inclusive culture where employees with wide-ranging backgrounds and qualities are highly motivated, engaged and connected. We do not discriminate against one’s race, age, gender, religion, ethnicity, disability, or nationality. During the Reporting Period, there were zero incidents (FY2024: Nil) of discrimination reported and we have achieved our short-term target.

As of 31 May 2025, we had a workforce of 89 full-time employees (FY2024: 97) for our operations across the Group with 70% (FY2024: 90%) length of service under 5 years and with 30% (FY2024: 10%) length of service from 5 to 10 years. 9% of our employees hold managerial positions (FY2024: 13%), while 91% are non-managerial (FY2024: 87%). Our headcounts are distributed as follows:

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Employee by Gender Group Employees by Age Group
71%
65%
63%
59%
35% 39%
29% 31%
6%
2%
FY2025 FY2024 FY2025 FY2024
< 30 years old 30-50 years old
Male Female
> 50 years old
Employees by Nationalities
75%
63%
22%
15%
6% 0% 3% 1% 5% 1% 4% 5%
FY2025 FY2024
Singapore Chinese Indian Malaysian Indonesian Others
Management by Gender Group Management by Age Group
85%
75%
88%
77%
25%
15%
12% 8% 15%
0%
FY2025 FY2024 FY2025 FY2024
Male Female < 30 years old 30-50 years old > 50 years old
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Equal Opportunity

Our recruitment of staff is based solely on merit and qualifications, without discrimination of race, age, gender, religion, or ethnicity. Every employee plays an essential role in our Company, and we pay the utmost attention to our employees’ general well-being. To promote equal opportunity, employees are recruited as either permanent team members or on a contractual basis, utilising a diverse array of avenues such as online job platforms, professional consultants, and internal endorsements.

The recruitment procedure diligently follows established protocols, encompassing initial screenings, technical assessments, dialogues, offers and comprehensive onboarding procedures for selected individuals. Acknowledgment of staff contributions takes shape through routine salary evaluations and celebratory bonuses. The recruitment framework encompasses application evaluation,

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candidates shortlisting, interviews, and HR-facilitated compensation deliberations for the selected candidates. As such, we have started tracking our employee new hires and turnover during the year, as disclosed below.

New Hires FY2025 FY2025 FY2024 FY2024
Number % Number %
Overall New Hires
15
17 46 47
By Gender
Male 9 10 31 32
Female 6 7 15 15
By Age
< 30years old 8 9 24 25
30 – 50years old 5 6 19 19
> 50years old 2 2 3 3
Turnover FY2025 FY2024
Number % Number %
Overall Turnover 23 26 25 26
By Gender
Male 20 23 18 19
Female 3 3 7 7
By Age
< 30years old 3 3 11 11
30 – 50years old 15 17 14 153
> 50years old 5 6 0 0

Team Building

As part of our commitment to the Social pillar of EESG, the Company recognises that employee wellbeing and engagement are essential to a sustainable workplace. During the year, we organised simple yet meaningful initiatives to foster team bonding and a positive work culture. These included monthly birthday celebrations to show appreciation and strengthen employees’ sense of belonging, team lunches and dinners to mark successful project completions and encourage open communication outside the work environment, as well as festive celebrations within the office to embrace cultural diversity and create a spirit of inclusivity. Together, these initiatives contribute to a collaborative and engaging workplace, promote stronger connections among colleagues, and support the overall well-being of our people, aligning with our commitment to building a resilient and engaged workforce.

3 Figure has been restated due to rounding difference

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The Group has achieved its short-term target of engaging employees and maintaining diversity in gender, nationality, and age. Team-building and motivational activities were carried out during the year, and no cases of unlawful discrimination were reported, showing the Group’s commitment to fair and equal opportunities for all.

OCCUPATIONAL HEALTH AND SAFETY

We are committed to safeguarding our employees’ health and safety against any potential workplace hazards. Ensuring our employees’ safety and health in the workplace is one of our

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top priorities, and our ultimate target is to have a zero-accident workplace. We are committed to reducing any risks related to safety and health through effective risk management. In FY2025, the Company continued to implement a hybrid working arrangement, contributing to the reduction of significant occupational health and safety risks across our operations. This flexible approach has allowed us to prioritise employee well-being while maintaining a safe and healthy working environment, ensuring that potential hazards and negative impacts on occupational health and safety are effectively minimised.

Work-Related Injuries For Employees FY2025 FY2024
The number and rate of fatalities as a result of work-related injury Nil Nil
The number and rate of high-consequence work-related injuries Nil Nil
The number and rate of recordable work-related injuries Nil Nil

In FY2025 we have achieved our short-term target of zero occurrence of workplace fatality and nonfatal workplace injuries (FY2024: Nil).

GOVERNANCE

CORPORATE GOVERNANCE

We believe that strong governance is the key to a sustainable business. The Board and management of TOTM Technologies are committed to maintaining a high standard of corporate governance. The Company understands that good corporate governance is an integral element of a sound corporation, enabling it to be more transparent and forward-looking. Please refer to our Corporate Governance Report, pages 18 to 47 of the Annual Report.

Our overall Singapore Governance and Transparency Index score assessed by the National University of Singapore Business School is 69.5 for FY2025 (FY2024: 71).

We believe that our constant drive for corporate excellence will allow us to establish a more transparent, accountable, and equitable system, thereby increasing the value of the Company and its value to our stakeholders. We will continue to comply with the Code of Corporate Governance and meet all requirements that are expected of us by our stakeholders.

The Group achieved its short-term target through adherence to the Code of Corporate Governance.

BUSINESS ETHICS AND COMPLIANCE

TOTM Technologies takes serious consideration of any possibilities of conflict of interest during our hiring procedures. Our Code of Conduct clearly states our expectations from our staff and

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the consequences if any of the rules are violated or standards are not met. We also have clear and fair grievance procedures. Our target is to ensure allegations received are promptly addressed. There were no allegations received in FY2025 and FY2024.

Business ethics are communicated to all our heads of business units regularly and they must fully understand that compliance with rules and regulations is a key part of running a responsible business. Topics covered under the ethics training are comprised of the following:

Honesty

To act honestly and in the best interest of the Company.

Integrity

By doing what they think is right even when there is great pressure to do otherwise; they are principled, honorable, and upright.

Promise-keeping & Trustworthiness

Make every reasonable effort to fulfil the letter and spirit of their promises and commitments.

Accountability

Ethical executives acknowledge and accept personal accountability for the ethical quality of their decisions and omissions to themselves, their colleagues, their companies, and their communities.

Cyber security and data privacy are not only important for compliance, but also in safeguarding both our data and that of our customers. We have taken measures to guard against cyber risks for both our internal and external stakeholders by complying with the Personal Data Protection Act Policy. Our subsidiary in Indonesia obtained ISO 270001 in relation to Personal Data Protection Act. This policy also applies to our employment process where the privacy of all applicants is safeguarded and access to personal data is restricted to authorised persons or senior management on a need-toknow basis.

In FY2025, there were no fines or non-monetary sanctions for non-compliance with laws and regulations, with the Group achieving its short-term target of maintaining zero significant fines or non-monetary sanctions. As part of our commitment to uphold secured data privacy, we will continue to ensure compliance and maintain this outcome going forward.

ENVIRONMENTAL COMPLIANCE

Here at TOTM Technologies, we view compliance with relevant codes and regulations on environmental issues as mandatory. The Group has implemented policies and procedures designed to ensure compliance with the relevant laws and regulations and prevent environmental pollution and resource depletion with due diligence. We have compiled a Legal & Other Requirements Register for relevant legal and other requirements that the Group needs to comply with. For example, we are in compliance with the Environmental Public Health Act and Regulations, Environmental Protection and Management Act and Regulations and Smoking Act. We have taken steps at all worksites to ensure the requirements are met throughout the duration of the projects.

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Compliance With Environmental Laws
And Regulations
FY2025 FY2024
Instances for which fines were incurred Nil Nil
Instances for which non-monetary
sanctions were incurred
Nil Nil

In FY2025, we have achieved our short-term target of zero incidence of non-compliance with laws, environmental rules and regulations resulting in significant fines or sanctions (FY2024: Nil). As part of our on-going commitment, we strive to continue being in full compliance with laws, environmental rules and regulations to not result in significant fines or sanctions.

ENTERPRISE RISK MANAGEMENT

The Board acknowledges its responsibilities for the overall internal control framework and governance of risk, ensuring that the management maintains a sound system of risk management and internal controls to safeguard the interests of the Company and its shareholders. Currently, the Group is working towards updating its existing ERM framework to incorporate climate-related risks into overall risk framework in the future.

The Board, assisted by the AC, reviews annually, and ensures that a sound system of risk management and internal controls is maintained by the Group to safeguard shareholders’ interests and the Group’s assets and determines the nature and extent of the significant risks which the Group is willing to take in achieving its strategic objectives. The Group has implemented a system of internal controls designed to provide reasonable assurance that assets are safeguarded, proper accounting records are maintained, operational controls are adequate, and business risks are suitably managed as we implement the commitments made to responsible business conduct. The Board, with the assistance of the AC, oversees the management in the design, implementation and monitoring of the risk management and internal control systems, and reviews the adequacy and effectiveness of such systems at least annually. Please refer to Corporate Governance Report, pages 37 to 41 of the Annual Report, for more detailed information.

In FY2025, sustainability-related risks are not yet integrated but are considered when we make business and operational decisions. We will continue to strive to identify, manage, and respond timely to any gaps in sustainability reporting and regulatory compliance.

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CLIMATE-RELATED DISCLOSURES

As the effects of climate change become increasingly evident, the importance of addressing climaterelated risks and seizing opportunities for broader impact is clear. TOTM Technologies recognises the focus on climate-related disclosures to foster a more sustainable and resilient future.

Considering that transitioning to and complying with such disclosures requires integrating various functions, resources and efforts within an organisation, the management is committed to providing the TCFD-aligned climate disclosures in years to come as the Group is currently occupied with other strategic and operational priorities. As a concrete measure, we will be fostering constructive dialogue during board meetings to facilitate climate action in decision-making, conducting a comprehensive assessment of our current practices to identify strengths and pinpoint areas for improvement, and developing a well-defined action plan that aligns with the TCFD guidelines.

Climate-related
Disclosure Pillar
Recommendations TOTM Technologies’ Responses
Governance a) Describe
the
board’s
oversight
of
climate-
related
risks
and
opportunities.
In the coming years, the Group will look into
formalising
climate-related
governance
structure
by
defining
the
roles
and
responsibilities of the Board in oversight of
climate-related risks and opportunities for the
Group’s climate agenda.
b) Describe management’s
role in assessing and
managing climate-related
risks and opportunities.
The key senior management team is tasked
with the implementation of sustainability
initiatives and is responsible for leading the
Group’s
sustainability
efforts
and
development. The Group will work towards
establishing climate governance roles and
responsibilities at the management level in
the future to facilitate the identification,
assessment and management of climate-
related risks and opportunities.
Strategy a) Describe
the
climate-
related
risks
and
opportunities
the
organization
has
identified over the short,
medium, and long term.
The identification of climate-related risks and
opportunities
requires
a
multi-faceted
approach, integrating several functions and
efforts within an organisation. The Group is
committed to establishing the necessary
process to identify potential climate-related
risks and opportunities that may impact the
Group over the short-, medium-, and long-
term.
b) Describe the impact of
climate-related risks and
opportunities
on
the
organization’s
businesses, strategy, and
financial planning.
At the moment, the management is occupied
with other operational priorities, and once the
climate-related risks and opportunities are
being identified by the Group, we will assess
their impact on our business strategy and
financial planning.

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c) Describe the resilience of
the
organization’s
strategy,
taking
into
consideration
different
climate-related
scenarios,
including
a
2°C or lower scenario.
The Group will continue focus on building
internal capabilities and resources first before
formulating a climate-resilient strategy, taking
into
account
various
climate-related
scenarios that the Group might encounter in
the coming years.
Risk Management a) Describe
the
organization’s processes
for
identifying
and
assessing climate-related
risks.
The Group will continue to develop our
internal capabilities to come out with a
process for identifying and assessing climate-
related risks and opportunities across our
operations that have potential financial
impacts in the future.
b) Describe
the
organization’s processes
for
managing
climate-
related risks.
The Group understands how the climate-
related
risks
can
affect
the
Group’s
operations. As such, we are in the midst of
expanding our internal expertise in order to
develop risk management processes that are
suitable for the Group in managing climate-
related risks.
c)Describe how processes
for identifying, assessing,
and managing climate-
related
risks
are
integrated
into
the
organization’s overall risk
management.
The Group has yet to develop the processes
for identifying, assessing and managing
climate-related risk as of now. We will work
towards integrating climate-related risks into
our Company’s risk management process to
better monitor and manage such risks that
may
potentially
affect
our
business
operations.
Metrics and
Targets
a) Disclose the metrics used
by the organization to
assess
climate-related
risks and opportunities in
line with its strategy and
risk
management
process.
Due to the Group’s business operation nature
and lack of internal capacities, it is
challenging to gather reliable climate-related
data as of date. However, the Group has
plans to disclose climate-related metrics in
our Report in the future.
b) Disclose Scope 1, Scope
2, and, if appropriate,
Scope 3 greenhouse gas
(GHG) emissions, and the
related risks.
The Group understands the importance of
disclosing our carbon footprints such as
Scope 1, 2 and 3 GHG emissions. While
building our internal expertise for climate-
related matters, the Group is committed to
disclosing Scope 1 and Scope 2 in FY2026.
c) Describe the targets used
by the organization to
manage
climate-related
risks and opportunities
and performance against
targets.
The Group will work towards setting and
disclosing climate-related targets to better
monitor our sustainability performance in the
near future after we build up our internal
capacity to identify and manage climate-
related risks and opportunities.

Page | 19

GRI CONTENT INDEX

Statement of Use TOTM Technologies Limited has reported the information cited in GRI Content
Index for the period of 1 June 2024 to 31 May 2025 (“FY2025”) with reference to
the GRI standards 2021.
TOTM Technologies Limited has reported the information cited in GRI Content
Index for the period of 1 June 2024 to 31 May 2025 (“FY2025”) with reference to
the GRI standards 2021.
GRI 1 Used GRI 1: Foundation 2021
Applicable
GRI
Sector Standard(s)
Not applicable
GRI Standard Disclosure Location
GRI
2:
General
Disclosures 2021
2-1 Organizational details 5
2-2 Entities included in the organization’s sustainability
reporting
3
2-3 Reporting period, frequencyand contactpoint 3 to 4
2-4 Restatements of information 13
2-5 External assurance 4
2-6
Activities,
value
chain
and
other
business
relationships
5
2-7 Employees 11 to 12
2-8 Workers who are not employees None
2-9 Governance structure and composition AR 23 to 24
2-10 Nomination and selection of the highest governance
body
AR 27 to 30
2-11 Chair of the highestgovernance body AR 26
2-12 Role of the highest governance body in overseeing
the management of impacts
3
2-13 Delegation of responsibilityfor managingimpacts 3 to 4
2-14 Role of the highest governance body in
sustainabilityreporting
3
2-15 Conflicts of interest AR 18 to 19
2-16 Communication of critical concerns 6, 9
2-17 Collective knowledge of the highest governance
body
3
2-18 Evaluation of the performance of the highest
governance body
AR 31
2-19 Remunerationpolicies AR 32 to 33
2-20 Process to determine remuneration AR 33 to 34
2-21 Annual total compensation ratio AR 34 to 35
2-22 Statement on sustainable development strategy 3 to 4
2-23 Policycommitments 10
2-24 Embedding policycommitments 10
2-25 Processes to remediate negative impacts 9
2-26 Mechanisms for seeking advice and raising
concerns
9
2-27 Compliance with laws and regulations 15 to 17
2-28 Membershipassociations None
2-29 Approach to stakeholder engagement 6
2-30 Collective bargaining agreements None
GRI 3: Material Topics 3-1 Process to determine material topics 7

Page | 20

2021 3-2 List of material topics 7
3-3 Management of material topics 8 to 17
GRI 201: Economic
Performance 2016
201-1 Direct economic value generated and distributed 8
GRI
205:
Anti-
corruption 2016
205-3 Confirmed incidents of corruption and actions
taken
9
GRI
308:
Supplier
Environmental
Assessment 2016
308-1 New suppliers that were screened using
environmental criteria
10
GRI 403: Occupational
Health and Safety2018
403-9 Work-related injuries 14 to 15
GRI 405: Diversity and
Equal
Opportunity
2016
405-1 Diversity of governance bodies and employees 11 to 13

Page | 21