Corporate Governance Policy

ALLY REIT operates under the principles of good corporate governance and is committed to ensuring its practice through a number of key documents and policies.

ALLY’s corporate governance is based upon external law, regulations, and internal rules that are set forth in the “Code of Conduct” as well as the “Corporate Compliance Policy” and “Anti-Corruption Policy”. Moreover, ALLY has implemented the COSO enterprise risk management framework to ensure the highest standards of governance for all stakeholders.

Code of conduct

Company Code of Conduct
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Charters

Board of Directors Charter
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Investment Committee Charter
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Others

Corporate Compliance Policy
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Internal Control and Risk Management

Internal Audit Department performs the duty in auditing and assessing the adequacy of internal control system of departments in charge in part relating to management of the REIT

in accordance with the determined operating procedure. The audit and assessment of this internal control system shall be in accordance with annual audit plan approved by the Audit Committee. As Internal Audit Department is a department with operating independence, the performance result therefore shall be reported directly to the Audit Committee. According to the assessment of the adequacy of internal control system, the Internal Audit Department commented that internal control system in part relating to REIT management is circumspect and proper. The adequate personnel have been assigned to perform the duties under clear segregation of duties and responsibilities, resulting in efficient operation in accordance with internal control system. In addition, the operation of the Property Manager has been monitored and controlled, resulting in circumspect and proper control and monitoring on utilization of the REIT’s assets.

Enterprise Wide Risk Management Policy

Anti-Corruption Policy

Ally Reit together with the subsidiary places significant importance on the subject of anti-corruption, and hence, has issued a related policy and guidelines for business operation.

The Company shall operate with earnest commitment to honesty, transparency, fairness, the principle of good corporate governance, business ethic and anti-fraud and corruption of all facades, both directly and indirectly, be it a request for, acceptance or provision of bribery.

Anti-Corruption Policy
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A Declaration of Intent-Collective Action Coalition Against Corruption (CAC)
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Whistleblower

The Board of Directors shall ensure that the Company has a mechanism to receive complaint and operation in receiving complaints, as well as disclose the process and channel of receiving on the Company’s website as follows: