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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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Page | 1
| 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