The Legal Profession (Professional Conduct) Rules 2015 of Singapore, which regulate how we conduct our practice, requires us to ensure that all our clients are given certain basic information at the start of any new engagement.

This Client Care Policy (“Client Care Policy”), therefore, contains information about our procedures,
professional charges, the basis upon which we undertake work for you and related matters. Please read it carefully.

A legal style explanation of the extent of our obligations to each other is set out in the pages that follow (also available on our website) but you can be assured that if at any time you have a question or concern about our services, you need only ask, and we will respond.

We look forward to being of service to you because you matter to us.

1. Altum Law Corporation

1.1 Altum Law is a trading title used by Altum Law Corporation.

1.2 Unless otherwise agreed with you, all our legal work and services for you are provided exclusively
through Altum Law Corporation.

1.3 As independent legal advisers, we are independent of the control and influence of any other business, insurers, or financial institution. We are free to, and will always, put the interest of our clients first.

1.4 Altum Law (or “the Firm”) is licensed as a Singapore Law Practice by the Legal Services Regulation
Authority and is incorporated as a law corporation with limited liability. There are four principal
lawyers licensed to practise Singapore Law, supported by associates who are lawyers licensed to
practise Singapore Law or who are lawyers qualified in another jurisdiction.

1.5 This does not mean that every individual doing work for the Firm is qualified as an Advocate and
Solicitor of the High Court of Singapore. However, we would assure clients that the Firm is bound by
the professional rules and obligations that apply to a Singapore Law Practice.

1.6 We are registered for Goods and Services Tax (“GST”) and our GST registration number is 201418597K.

1.7 We maintain professional indemnity insurance. Details of our insurers and the coverage of our policies are available upon request, and you should satisfy yourselves on the adequacy of such coverage for engaging us.

2. Our Aim

We aim to offer you and all our clients good quality legal advice with a personal service at fair cost.

3. Our Commitment to You

3.1 We value your instructions, and we hope that together we will be able to achieve your aims as
efficiently and cost effectively as possible.

3.2 We will:

• Represent your interests and keep your business confidential.
• Explain to you the legal work that may be required and the prospects of a successful outcome.
• Make sure that you understand the likely degree of financial risk that you will be taking on.
• Keep you regularly informed of progress or, if there is none, when you are next likely to hear from us.
• Try to avoid using technical legal language when writing to you.
• Deal with your queries and progress the matter promptly.

4. Our Engagement

4.1 We will usually provide you with our Letter of Engagement prior to the start of any new engagement.
The Letter of Engagement is the primary document which includes details of what you asked us to do,
explain how our charges will be calculated and (where applicable or possible) provide our
agreed/fixed fee or an estimate of our charges, and together with our Terms of Business and this
Client Care Policy, constitute or form our Terms of Engagement. In the event of any conflict or
inconsistency, the Letter of Engagement shall prevail. No variation to these terms shall be effective
unless agreed in writing by one of the Directors of Altum Law.

4.2 Your commencement of, or continuing instructions to us will amount to your acceptance of the Terms of Engagement even in cases where there is no Letter of Engagement, or you have not signed and returned a copy of it to us.

4.3 The Letter of Engagement sets out the Director in charge and other team members who will carry out most of the work in a matter, although there may be other lawyers who may step in on a temporary
basis, for instance when team members go on leave, or where it may be more cost-effective to
allocate routine matters to a less senior member of the Firm.

4.4 We try hard to avoid changing the lawyers who are handling your work but if this cannot be avoided,
we will notify you promptly and tell you why the change was necessary. You will still be liable to pay
all of our charges and expenses for the work we have completed irrespective of who has undertaken
the work for you and whether or not you have been advised of the change of personnel.

4.5 Depending on the work we are doing for you, it is sometimes advantageous to use the specialist skills of other members of other firms, whether on a joint engagement basis or otherwise, as we may
consider appropriate. However, we shall notify you before any such engagement and unless
otherwise agreed, their fees will be included in the fees charged by us.

4.6 We will separately explain to you the issues raised in your matter and advise you about its likely stages and estimated timetable. We will keep you informed of progress and advise you on whether the likely outcome will justify the likely charges, expenses and risk involved, from time to time as necessary.

5. Your Responsibilities

5.1 To enable us to advise you fully, we need to have full details of the matter. You can help us by giving
full clear instructions, providing all relevant documents, acting promptly, and telling us about any time
limits of which you are aware.

5.2 We may require you to provide personal details including confirmation of your identity and details of
your personal finances in order to satisfy our obligations under the Corruption, Drug Trafficking, and
Other Serious Crimes Act 1992 and the Terrorism (Suppression of Financing) Act 2022, all regulations
issued by the Singapore Law Society and other government authorities before we are able to proceed
on your instructions.

5.3 If you are an entity or legal arrangement such as a company or partnership, it is your responsibility to
ensure our appointment has been duly approved and authorised by way of a board resolution or such
other relevant corporate approval(s) as may be required.

5.4 Correspondence, telephone calls and attendances cost money. Please make every effort to avoid
unnecessary expenses. For example, the time spent chasing you, or other parties, to supply
information will increase your overall costs. By helping to keep the costs down, you are benefiting
yourself. Do not forget to tell us if you change your address or if you plan to go away from home for
any period of time.

5.5 It is your responsibility, not ours, to review your affairs from time to time. Unless we otherwise agree
with you in writing, our retainer ends once a matter is completed and the file is closed. We do not
accept continuing responsibility to advise you on the completed matter or changes in the law that
might affect you or any advice previously given. In particular, we will not advise you of ongoing
circumstances (e.g., rent reviews or the service of notices when leases are due to end).

6. Our Responsibilities

6.1 In acting as your lawyer, the primary responsibility of the Firm will be to our client on record under
the Letter of Engagement. We may also have additional responsibilities such as to the Police, the Law
Society of Singapore, the Legal Services Regulation Authority, the Singapore Courts, insurers in
litigation matters or to your lender in a property transaction if we are instructed to act for them too.
We may, therefore, have to advise you to provide information to them and we may be compelled to
give information to them irrespective of your instructions.

6.2 The benefit of our advice is personal and confidential to you only. Except where it is referred to
elsewhere, we will preserve confidentiality. If you wish to pass on the benefit of that advice to others
or you ask us to do so, you may, but that other person will not as a result have any enforceable right
against us under these Terms of Engagement.

6.3 Unless you inform us otherwise, we shall communicate with, and assume that any director, officer,
employee, shareholder, partner, sole proprietor or owner of a company, corporation or entity
appointing, instructing or otherwise communicating with us is duly authorised to do so, and otherwise
to act on behalf of that company, corporation or entity in all matters relating to that company,
corporation or entity.

6.4 We may advise you to obtain advice from other professionals such as accountants or financial advisers. We are not liable for any advice given to you (whether or not obtained by us on your behalf as your agent) by them but you will be liable for our charges and expenses incurred in obtaining and
proceeding with that advice as instructed by you.

6.5 We aim to provide an efficient and comprehensive service to the highest standards. We will keep you informed of the progress of the matter throughout, at each significant stage. This will usually be by e-
mail, but, for the sake of speed and economy, may take the form of simply copying correspondence
or emails to you. It may happen that you do not hear from us for periods at a time. That is not to say
that nothing is happening. We will be attending to the matter in its normal course, and we will notify
you as soon as anything of importance occurs. If, however, you would like a progress report at any
time, please contact the person acting for you or their secretary or assistant.
6.6 We are unlikely to have a detailed knowledge of your financial affairs, and our engagement or retainer
does not include advice on the financial or taxation implications of commercial matters. We are happy
to work with your accountant or financial adviser to structure a transaction in the best manner should
this be appropriate. In any event we strongly recommend you to seek advice from your accountant
or financial adviser where necessary. In addition, we will not be responsible nor liable for work that
is the responsibility of other professionals e.g. independent financial advisers, tax, valuation or
auditors, solicitors and legal counsel to other parties, legal counsel from other jurisdictions, company
secretaries and/or share registrars.
6.7 Our engagement by you and for you creates rights and obligations only between you and us and shall
not create or confer, nor is it intended to confer, upon any person other than the client on record any
right to enforce any of the Terms of Engagement (nor any other rights, remedies, obligations or
liabilities, except as expressly provided herein) which that person would not have had but for the
provisions of the Contracts (Rights of Third Parties) Act 2001 of Singapore. Our duty of care does not
extend to and we do not accept any liability or obligation to any person other than the client on record
including any holding company, subsidiaries or affiliated companies or other third parties.
6.8 While we will exercise reasonable care and skill in all matters undertaken by us, we do not guarantee
any particular outcome for the work we do for you. Our fees and your obligation to pay for them in
full are not dependent or contingent upon the business or commercial outcomes, nor the success or
completion of any transactions related to the work we do for you.
7. How we Calculate our Charges
7.1 Our charges may be calculated in one, or a combination, of a number of different ways.
• Hourly Rate: If there is no agreement on fees in advance, our charges will be calculated by
reference to the time spent by the personnel dealing with your matter. Time spent will
include meetings with you and others (where relevant); considering, preparing, and working
on papers; correspondence; travelling away from the office if necessary; and making and
receiving telephone calls.
For work of unusual complexity, urgency or importance or requiring attendance out of the
office or during unsocial hours we may increase the hourly rate to reflect these factors.
• Fixed or Agreed Fee: We will endeavor to agree on a fee in advance upon your request where
it is practicable to do so. This is for the service that will be explained to you. If something
unexpected happens to make the work more complex or requires more time spent than is
usual or anticipated, or where a formal legal opinion is required, we reserve the right to
increase the fee. However, we will inform you of this in advance.
Our professional fees quoted are based on various factors including the time anticipated to
be spent, the seniority of the lawyers involved, and other discretionary factors, such as the
nature of the transaction we are advising on, the value of the transaction, its urgency, novelty
and/or complexity, the degree of responsibility involved, the extent of liability to multiple
parties, the nature of applications and the anticipated duration of the engagement.
7.2 We will make administrative charges such as printing and stationery costs, or if we carry out a search
at The Accounting and Corporate Regulatory Authority (“ACRA”) or with any agency in connection
with our client due diligence process or the work that we are doing for you. The charge will depend
on the type of search and type and number of documents that we obtain. We will charge for travel
undertaken (for travelling to meetings or as required for purposes of carrying out our engagement),
overtime incidental charges (including transport and meal allowances for work done beyond normal
business hours where required by the exigencies of our engagement), telecommunication expenses
(for conference calls or overseas calls, where required), travelling incidental charges (including
international travel, board and accommodation expenses as required by the work we are doing for
you), ACRA and litigation/court filing or search fees required in connection with the work we are doing
for you.
7.3 A copy of our Terms of Business with further details of our hourly charge-out rates and administrative
charges is available upon request. Our hourly charge-out rates and administrative charges are
reviewed from time to time. We will only notify you of any changes if there is likely to be a substantial
increase of such charges as estimated to you. This does not affect fixed fees agreed in advance.
7.4 Disbursements will be shown separately on our invoices. Unless you ask us to do so, we will not usually
check with you before incurring disbursements or expenses on routine items. We will usually consult
with you before incurring non-routine items of expenditure.
7.5 If a third party such as an auditor, tax adviser, foreign counsel, an expert witness or an investigator or
other third-party service providers who may be engaged to provide services to you or on your behalf
is appointed for the purposes of the work we are doing for you, we may be liable to them for their
fees. In such event, in addition to your obligation to indemnify us, we will normally require you to
make an additional deposit to account sufficient to cover the anticipated third-party fees.
8. Goods and Services Tax
8.1 Our professional charges are exclusive of GST, which will be added to the charges.
8.2 GST is also payable on our administrative charges, including for disbursements such as ACRA,
Singapore Courts, and other governmental agency search fees.
8.3 We may from time to time make payments on your behalf, e.g. such as stamp duty, for which no GST
is payable. You will have to repay us for any expenses or payments we make on your behalf. We have
no obligation to make such payments unless you have provided the funds.
8.4 We will not charge GST for invoices where our services rendered can be considered as zero-rated
supplies provided you furnish us with the necessary evidence or confirmation of your eligibility to
qualify for this. The final discretion on whether to charge GST lies with us, and you agree to indemnify
us should there be a need to collect GST retrospectively.
9. Arrangements for paying our Charges
9.1. As we do not operate a trust or client account, we are not able to hold or receive any money from
you to hold in hand or on trust or escrow.
9.2. We may ask you to make payments in advance on account of disbursements or payments on your
behalf, for instance for stamp duty or fees payable to agencies. Please make any payments promptly
to avoid any delay in the progress of your matter.
9.3. All sums payable to us will be paid free and clear of (a) any bank charges and (b) deductions or
withholdings, whether or not required by law. If any withholdings are so required, you will pay us
such sum as will leave us with the same amount as we would have received in the absence of a
requirement to make a withholding.
9.4. The common law entitles us to retain any money, papers or other property belonging to you that
properly come into our possession pending payment of our costs, whether or not the property is
acquired in connection with the matter for which the costs were incurred. This is known as a “general
lien”. We are not entitled to sell property held under a lien but we are entitled to hold property,
other than money, even if the value of it greatly exceeds the amount due to us as our costs.
9.5. Although it may be the case that some other person agrees or is ordered to pay our charges, you will
remain personally responsible for paying our charges and expenses as and when they become due.
We will not refrain from or postpone our demand for payment of our charges and expenses by you
because someone else has agreed to or is under an obligation to pay them.
10. Money Laundering and Client Due Diligence
10.1. “Money laundering” is the process by which the proceeds of crime, and the true ownership of those
proceeds, is changed so that the proceeds appear to come from a legitimate source.
10.2. For the protection of all our clients, and to comply with statutory requirements, we operate a money
laundering and counter terrorism financing reporting procedure. In certain circumstances, we have
a legal obligation to reveal information to the appropriate authorities if we have any suspicion of
money laundering, without advising you that we are doing so. We cannot accept liability for any loss
(including consequential loss), damage or delay arising as a result of our compliance with any
statutory or regulatory obligations.
10.3. The onus is now on solicitors to “know their clients”. We will apply due diligence procedures to every
transaction and identify all clients thoroughly. We will endeavour to meet clients in person whenever
possible.
10.4. At the beginning of every new matter, we will conduct a risk assessment and, if necessary, require
you to complete a client due diligence questionnaire and supply proof of identity. This is similar to
procedures operated by banks and other financial institutions. We will have supplied you with a list
of the documents that we ask you to produce for this purpose. We are entitled to refuse to act for
you if you fail to supply appropriate proof of identity for yourself or for any principal whom you may
represent.
10.5. For partnerships we will follow identification procedures in line with those for individuals.
10.6. For work involving trusts identification procedures in line with those for individuals will be applied
to the trustees and underlying beneficiaries.
10.7. We reserve the right to request further information, as we shall decide depending on the
circumstances.
10.8. We may undertake “know your client” and “client due diligence” identity authentication
electronically. This will involve supplying personal details and information that you have supplied to
us to a third party electronically. By instructing us you consent to our doing this.
10.9. We may charge you costs and disbursements that we incur in complying with these procedures and
we may ask you for a payment on account for these.
11. Copyright
Copyright in all documents created by us for you belongs to us, although you may use those documents
for the particular purpose for which they were created. If you wish to use them for any other purpose you
should obtain our permission to do so.
12. Publicity
Unless we otherwise agree with you, we may at any time after public announcement of the matter we are
acting or advising you on, publish marketing and/or promotional materials relating to our involvement in
that matter.
13. Confidentiality
13.1. We shall keep your affairs and the information you and your advisers give to us confidential and we
will not disclose such information without your consent, except to partners, lawyers, employees, or
to other advisers or personnel appointed or employed by you where we consider it appropriate for
the person to know such information for the purposes of the matter that we are acting for you or as
stated below.
13.2. Certain laws (for example, those relating to money laundering, terrorism financing and tax fraud)
give power to authorities such as the police or tax authorities to inspect client information and take
copies of documents. In addition, in specific circumstances certain laws (including those relating to
suspicious transaction reporting) compel us to report information to the relevant authorities even in
the absence of a request. It is possible that, at any time, we may be requested by relevant authorities
to provide them with access to documents held by or information known to the firm, or to attend
interviews with them in connection with the work we have done for you. In the unlikely event that
such a situation arises, we shall be entitled to comply with such request without any liability to you,
to the extent that we are bound by law or any court order to do so, but, insofar as it is practicable or
permitted under the relevant law, we shall endeavour to notify you of the request or the sharing of
information.
13.3. We reserve the right to disclose any records or information which we may have in our possession or
come into possession relating to you and/or the matters which you have instructed us on from time
to time to our professional indemnity insurers or advisers.
13.4. In the course of advising other clients (whether in the past, present or future) we may have in our
possession or come into possession, confidential information which may be material to the matter
on which we are advising you. Confidential information we hold about you may be material to such
other clients’ matters. You agree that by putting in place appropriate safeguards to ensure that
access to the relevant confidential information is restricted, our duty of confidentiality to you will be
satisfied and that (notwithstanding that we hold confidential information relating to another person)
we may act for you and you will not seek to prevent us from acting for other clients by reason of our
holding your confidential information.
14. Data Protection
14.1. The Personal Data Protection Act 2012 of Singapore requires us to advise you that we hold your
details on our database.
14.2. We use the information you provide primarily for the provision of legal services to you and for related
purposes including:
• Updating and enhancing client records;
• Analysis to help us manage our practice;
• Statutory returns; and
• Legal and regulatory compliance.
14.3. Our use of that information is subject to your instructions, the Personal Data Protection Act 2012 of
Singapore and our duty of confidentiality. Our work for you may require us to give information to
third parties such as expert witnesses and other professional advisers. You have the right of access
under data protection legislation to the personal data that we hold about you. A copy of our Privacy
Policy is available upon request.
14.4. We may from time to time send you information which we think might be of interest to you. If you
do not wish to receive that information, please notify us in writing.
15. Storage and Retention of Files Documents
15.1. After completing the work, or termination of our engagement, we are entitled to keep all your papers
and documents while there is money owing to us for our charges and expenses.
15.2. We are unable to retain client files for an indefinite period. We will retain client files for different
periods of time depending on the nature of the work, but we will not, as a general rule, retain client
files or records beyond the statutorily prescribed period. We shall not be obliged in any event to
share or provide you or any other person with access to such files or records, unless required by law
or a court order to do so, and shall have full authority to destroy and/or delete the same without
seeking your consent or approval or notifying you further of the same.
15.3. Retrieval Costs: Normally we will not make a charge to retrieve a document from storage or to
handover documents to newly instructed lawyers. However, we may make a charge based upon the
time incurred for checking identity and instructions, reading papers, writing letters, printing
documents or other work necessary to comply with your instructions.
15.4. Please ensure that you keep safe letters, papers and documents, which you have which may in any
way at all relate to a matter. It is important that none are destroyed. Please place them in
chronological order. Parties have an obligation to disclose all relevant documents in any disputes.
16. Communications
16.1. We are happy to communicate with you in the manner most suitable and convenient to you. In
particular the use of the Internet, mobile applications such as What’s app messages, and e-mail can
greatly speed up communication and is a useful way of sending documents to you, other professional
advisers and the authorities. However, these medium or channels of communication are insecure,
and carry inherent risks in relation to privacy or confidentiality, timeliness or effectiveness. Messages
may pass through the hands of unregulated service providers, the networks used may be vulnerable
to hacking, and governments can undertake interception. We do not insure you against those risks,
which you accept and acknowledge. We do not use encrypted e-mail or messages. If you wish to
communicate using messages or e-mail you consent to this including confidential information in non-
encrypted form. If you do not wish us to do this please advise us accordingly. We cannot guarantee
the confidentiality of your mobile number or e-mail address or other confidential information in
messages or e-mail correspondence. In addition, you accept the risk of late, incomplete or inaccurate
transmissions, and transmissions that may be corrupted or which may contain worms, viruses or
Trojan horses.
16.2. The provision of our legal services may refer or relate to investments. All communications from us
will be legal communications and not financial communications. No communication from us is, nor
is it intended to be, an invitation or inducement (direct or indirect) to engage in investment activity.
17. Termination
17.1. You may terminate your instructions at any time by writing to us with one (1) month’s prior notice,
or three (3) month’s prior notice where we are providing corporate secretarial services (if applicable).
17.2. In some circumstances, we may consider we ought to stop acting for you. We would only do so with
good reason, for example, if you do not pay our outstanding fees and charges despite repeated
reminders, or do not comply with your obligations under the Terms of Engagement; if we are of the
opinion that you are asking us to conduct matters in such a way that your instructions conflict with
our duties to the Court or others; if you cannot give clear or proper instructions on how we are to
proceed; or if it is clear that you have lost confidence in how we are carrying out your work. We will
give you reasonable notice before we stop acting for you.
17.3. If you or we decide to terminate our engagement, you must still pay our charges and expenses
incurred up to the time of termination. Where there is an agreed retainer or fee for an agreed scope
of work and our appointment is terminated before completion of work, we will be entitled to a pro-
rated fee and all disbursements, costs and expenses properly incurred up to the time of termination.
In all other cases, we will be entitled to a reasonable fee and all disbursements properly incurred up
to the time of termination.
17.4. At the time of termination, we are entitled to exercise a lien (a right of possession) over all
documents and monies held on your account until full payment is received. In the event you decide
to appoint a new law practice, we will, as required by the Law Society’s Rules, release all documents
to them only upon receipt of an undertaking from your new lawyers to protect our right over your
documents handed over to them for outstanding legal costs.
18. Problems and Complaints
18.1. We want to provide the best possible service to our clients. We hope that you will never have cause
to complain but we wish to hear from you if you are not satisfied with our service or our bill of costs.
18.2. If you have any problem with the service we have provided for you then please let us know. We will
try to resolve any problem quickly. If for any reason we are unable to resolve the problem between
us, then we are regulated by the Legal Services Regulatory Authority which provides a complaints
and redress scheme in certain instances.
19. Miscellaneous
The applicable law to the contract between us is the laws of the Republic of Singapore. This is irrespective
of where in the world you reside or are located from time to time.
20. Conclusion
We are confident we will give you high quality service in all respects. We hope that by providing this
information at the outset we have addressed any immediate questions about the day-to-day handling of
your work and our Terms of Engagement. However, if you have any queries please do not hesitate to
contact us.