By Mak Yuen Teen
This is the second of a four-part series of articles on Raffles Education Corporation. It is based on a forthcoming case study to be included in Volume 10 of the Corporate Governance Case Studies published by CPA Australia and edited by Professor Mak Yuen Teen. While the case is written from public information and intended for discussion purposes, this series of articles includes some additional analysis and interpretation by Professor Mak. Any views expressed in this article are Professor Mak’s personal views.
Board of directors
Back in 2012, the REC board comprised eight directors – four independent directors (IDs) and four executive directors (EDs). Chew held the dual roles of Chairman and CEO, while Chew Kok Chor, who is unrelated to Chew, served as ED and Deputy CEO. They were joined by lead ID Henry Tan Song Kok (TSK), three other IDs, and two other EDs.[1] The IDs were actively involved in Singapore’s business and public sectors, with numerous credentials and extensive professional experience.[2]
TSK was the Chairman of the Audit Committee (AC) and joined the board on 1 September 2000.[3] Prior to joining REC, he set up his own accountancy firm in 1993 with Member of Parliament Sitoh Yih Pin.[4] Their business has since grown into what is known as Nexia TS Public Accounting Corporation – one of Singapore’s top mid-tier accounting firms.[5] TSK has also served on numerous boards of directors, often holding the positions of lead independent director and AC Chairman.[6]
Of the three other IDs, Dr Tan Chin Nam (TCN) and Teo Cheng Lok John (TCL) were appointed on 24 October 2008 while Lim Tien Lock, Christopher (LTL) joined on 19 November 2008.[7] TCN is a notable figure in the public sector with over 30 years of distinguished service in the Singapore Civil Service, holding key positions such as Permanent Secretary of the Ministry of Manpower and managing director of Singapore’s Economic Development Board.[8]
An experienced accountant, TCL is a co-founder and was a former senior partner of Baker Tilly TFW LLP (Baker Tilly).[9] He was in public accounting until 2010. Prior to 2017, REC’s annual reports stated that its “internal audit function is outsourced to a firm of certified public accountants” but did not mention the name of the firm. However, the annual reports from 2017 to 2020 stated that Baker Tilly was doing the internal audit for REC.[10] Since TCL is a member of the audit committee which oversees the internal audit function, this raises concern about a conflict of interest. In its response to questions from shareholders for its 2020 AGM, the company said that Baker Tilly was appointed as internal auditor in January 2015, about five years after TCL had retired from the firm.[11]
LTL has a strong background in business, including being group ED of Hotel Properties Limited and previously, Head of Corporate Finance of N M Rothschild & Sons (Singapore) Limited.[12]
Each of the IDs chaired one of the four committees – the AC, Nomination Committee (NC), Remuneration Committee (RC), and Risk Management Committee (RMC).
Recent changes
In late 2017 and early 2018, REC saw several resignations from its board of directors. LTL resigned on 30 November 2017, citing “relinquishing directorships in companies which are not related to Hotel Properties Limited” as the reason.[13] On 19 December 2017, the company announced that ED and Deputy CEO Chew Kok Chor was stepping down from his positions from 2 January 2018 due to “personal reasons”.[14] On 6 March 2018, lead ID TSK also resigned, citing “to facilitate renewal of the board”.[15]
To replace the directors who left, REC first appointed Lim How Teck (LHT) as ID on 6 March 2018. He became the lead ID and Chairman of the AC. LHT held directorships in more than 10 listed and unlisted companies, including ARA-CWT Trust Management (Cache) Ltd and NauticAwt Ltd, which are both public listed companies. Furthermore, he is on the board of directors of Heliconia Holdings Pte Ltd and Heliconia Capital Management Pte Ltd, which are wholly owned subsidiaries of Temasek Holdings.[16] LHT has also served as AC Chairman in a number of companies where he held directorships.[17]
LHT was previously Chairman and lead ID of SGX-listed Swissco Holdings Limited, before the company went into judicial management in 2017.[18] Other previous directorships in SGX-listed companies include Eng Kong Holdings Ltd, Mewah International Inc, ARA Asset Management Ltd, and Rickmers Trust Management Pte Ltd.[19] LHT has in-depth knowledge of the shipping industry – having been with NOL Group for over 25 years including holding the position of ED, Group CFO, Group COO and Group Deputy CEO – as well as experience in business finance and accounting.[20]
On 25 April 2018, Gan Hui Tin (GHT) was appointed as an ID. She is the managing director/advisor, business development in Southeast Asia, at BNP Paribas. She was previously the country head for HL Bank Singapore from 2001 to 2016 and has more than 30 years of experience in the banking industry. In considering her nomination, the board was also of the view that female representation would add diversity to the board.[21],[22]
Subsequently, TCN retired from the board on 29 October 2018.[23] Joseph He Jun (JHJ), who is a partner in the corporate mergers & acquisitions and the capital markets practices, as well as Head of the China Practice, in Wong Partnership LLP was appointed to the board as a non-independent and non-executive director (NINED) on 5 November 2018.[24] In REC’s 2019 annual report, it was disclosed that JHJ had previously acted for Hebei Oriental Zhuyun Property Development Co., Ltd. – a REC subsidiary – in the divestment of four land parcels in the Langfang Development Zone, Hebei Province, China.[25] This probably explains why he is not considered independent. As at the date of appointment, he held 20 directorships in various listed and unlisted companies, including BRC Asia Limited, which is listed on the SGX.[26]
On 15 November 2019, Liu Ying Chun (LYC) was appointed as a NINED. He is the CEO of Oriental University City Holdings (H.K.) Limited (OUCHK), a subsidiary of REC a company which is listed on the Hong Kong Stock Exchange. LYC is registered as a valuer with the China Appraisal Society, and is a qualified auditor accredited by China’s National Audit Office.[27],[28] However, it is rather puzzling that after less than a year, he retired and did not seek re-election at the company’s AGM on 30 October 2020.
In the 2018 annual report, LYC appeared for the first time among the list of top 20 shareholders, with a 2.84% stake as of 24 September 2018.[29] As of 25 September 2020, he held a 2.86% stake.[30] LYC’s stake in REC was to become one of the major flashpoints in the battle between Oei Hong Leong (OHL), a minority but substantial shareholder, and CHS.
On 25 February 2021, Ng Kwan Meng (NKM) was appointed as ID. NKM is chairman and a non-executive director of SP Group Treasury Limited, non-executive director of British and Malayan Holdings, British and Malaysian Trustees and Tasek Jurong, and a director of Singapore Power. He had formerly held management positions in entities in the United Overseas Bank group.
TCL, who had served on the board as an ID since October 2008, resigned on 1 July 2021, with REC citing “the board’s renewal and rejuvenation process” as the reason.[31] In his place, Lim Siew Mun (LSM) was appointed as an ID and member of all the four board committees.[32] LSM had never served as a director of a listed company and was required to attend training prescribed by SGX. She is a mental health professional, the Governor of the Cheshire Home, a member of the Living Waters Methodist Church, and serves on various committees of the Home and the Church.
With these board changes, the current REC board of directors now consists of six board members, with CHS as Chairman, four IDs and one NINED.[33] CHS is the only remaining member of the REC board that was in place in 2012.[34]
It appears that none of the IDs and NINEDs over the years had any prior working experience in the education sector, and none of the current ones have significant experience in either the education or property sector. Is the board of directors able to challenge management and understand issues critical to the success of the business if none of them has significant experience in the businesses that REC is in? CHS and his family members who are involved in the business also appear to have limited working experience in the property sector prior to REC’s diversification into that sector.
Remuneration
REC’s annual reports state that “the Group advocates a performance-based remuneration system that is directly linked to corporate and individual performance, both in terms of financial and non-financial, and the creation of shareholder wealth by incorporating appropriate key performance indicators.” The RC is responsible for the establishment of a framework for attracting, retaining and motivating senior management staff through competitive compensation and progressive policies; the annual review and approval of the remuneration for directors and senior management staff; and the administration of the company’s employees’ share option scheme and performance share plan. It is disclosed in the annual reports that the RC has access to expert advice from external remuneration consultants where required.[35] These are nice boilerplate statements but the governance of remuneration at REC is found rather wanting.
Remuneration details
REC’s director remuneration is disclosed in bands of S$250,000 in its annual reports. Between FY2012 and FY2020, company directors apart from CHS and the other EDs received director fees of below S$250,000.[36] For FY2020, REC only disclosed CHS’s remuneration in a band of S$500,000.
The disclosure of remuneration amounts is not compliant with the Singapore Code of Corporate Governance (SCCG) which recommends disclosure of the remuneration of individual directors in exact amount, and for FY2020, the remuneration band for CHS has also widened compared to the past few years. Why does REC choose to be opaque with the disclosure of remuneration amounts of the NEDs and CHS? It is not as if disclosure of exact amounts expose them to risk of being poached to serve as NEDs or management of other companies.
I believe that companies which do not disclose the exact remuneration even for their IDs and NINEDs, where there is absolutely no good reason to be opaque, are sending an important negative message about the mindset of these directors regarding transparency or their lack of influence in the company. After all, IDs in particular are supposed to champion transparency and it should start with insisting that their own remuneration be disclosed.
CHS’s remuneration across the years is summarised in Table 1. Over the most recent four financial years, CHS’s remuneration comprised solely of fixed salary with no variable remuneration, likely due to the poor performance of REC. Since REC is not fully transparent about the remuneration of CHS, it is difficult to determine the drivers for the trend in his remuneration over the years. However, we can see that his fixed salary has increased from a range of S$750,001 to $1 million in FY2012 to a range of S$1 million to S$1.5 million in FY2020. Since his fixed salary assuming the upper band in FY2015 is marginally lower than the fixed salary assuming the lower band for FY2016 (calculated using the percentage of total remuneration made up of fixed salary), his fixed salary likely increased in FY2016. In FY 2019, his fixed salary fell from a band of S$1,000,000 to S$1,250,000 to a band of S$850,000 to S$900,000, but that did not last long as it increased to a band of S$1,000,000 to S$1,500,000 in FY 2020. What is the reason for increasing the band to S$500,000 when disclosing CHS’s remuneration in FY2020? His total remuneration has fluctuated more wildly over the years, due to changes in variable remuneration.
| Financial year | Remuneration | Band disclosed in REC’s annual report | Salary assuming lower band | Salary assuming upper band |
| 2012 | 100% salary | Between S$750,001 and S$1 million | S$750,001 | S$1 million |
| 2013 | 38% salary
62% others |
Between S$2 million to S$2.25 million | S$760,000 | S$855,000 |
| 2014 | 14% salary
86% others |
Between S$5 million to S$6 million | S$700,000 | S$840,000 |
| 2015 | 47% salary
53% others |
Between S$1.75 million to S$2 million | S$822,500 | S$940,000 |
| 2016 | 63% salary
37% others |
Between S$1.50 million to S$1.75 million | S$945,000 | S$1,102,500 |
| 2017 | 100% salary | Between S$1 million to S$1.25 million | S$1,000,000 | S$1,250,000 |
| 2018 | 100% salary | Between S$1 million to S$1.25 million | S$1,000,000 | S$1,250,000 |
| 2019 | 100% salary | Between S$ 850,000 to S$900,000 | S$850,000 | S$900,000 |
| 2020 | 100% salary | Between S$1 million to S$1,500,000 | S$1,000,000 | S$1,500,000 |
Table 1: Chew’s remuneration between FY2012 and FY2020[37]
At REC, directors are often invited to participate in meetings of committees that they are not part of, including the EDs. CHS attended AC and RC meetings on multiple occasions, despite only being a member of the NC.[38],[39] In FY2018 and FY2019, in addition to being part of the NC, Chew became a member of the RC and RMC as well.[40],[41] This is despite the SCCG recommending that the RC should only comprise of NEDs. REC did not disclose when CHS became a member of the RC and RMC but since he replaced LTL on these two committees and LTL resigned on 1 December 2017, it is likely that he joined the committees at that time. On 15 November 2019, CHS resigned from the RC and RMC.[42]
Table 2 shows the Chairman and members of the RC from FY2012 to FY2020, and CHS’s involvement in the RC. We can see that CHS was actively involved in the RC either as a member or through attendance at the RC meetings on an ex-officio basis. As CHS is the Chairman and CEO, and several family members hold management positions in the group, his RC membership and/or regular attendance at RC meetings raises concerns about conflict of interest in setting his remuneration and that of his family members. REC’s corporate governance statements do say that “any director who has an interest that may present a conflict will either recuse himself from participating in the deliberations and voting on the matter or declare his interest and abstain from decision-making”. To what extent is recusal practised when it comes to discussing remuneration matters concerning CHS and his family members?
It is common for board committees to invite certain management members to attend meetings on an ex-officio basis to provide information and views related to their responsibilities. However, the active participation of CHS in board committee meetings may raise concerns as to whether these committees, which are supposed to be independent, would be able to function independently and effectively.
| Financial year | Remuneration committee chairman | Remuneration committee members | CHS’s role in remuneration committee |
| 2012 | Teo Cheng Lok John (wef 20/9/12) | Tan Chin Nam, Lim Tien Lock Christopher (Chairman until 20/9/12) | Attended 1 out of 1 meeting by invitation |
| 2013 | Teo Cheng Lok John | Tan Chin Nam, Lim Tien Lock Christopher | Attended 1 out of 1 meeting by invitation |
| 2014 | Teo Cheng Lok John | Tan Chin Nam, Lim Tien Lock Christopher | Attended 1 out of 1 meeting by invitation |
| 2015 | Teo Cheng Lok John | Tan Chin Nam, Lim Tien Lock Christopher | Attended 1 out of 2 meetings by invitation |
| 2016 | Teo Cheng Lok John | Tan Chin Nam, Lim Tien Lock Christopher | Attended 1 out of 1 meeting by invitation |
| 2017 | Teo Cheng Lok John | Tan Chin Nam, Lim Tien Lock Christopher | Attended 2 out of 3 meetings by invitation |
| 2018 | Teo Cheng Lok John | Tan Chin Nam, Chew Hua Seng | Attended 2 out of 3 meetings as member |
| 2019 | Teo Cheng Lok John | Gan Hui Tin, Chew Hua Seng (Lim How Teck attended 1 meeting by invitation) | Attended 3 out of 3 meetings as member |
| 2020 | Teo Cheng Lok John | Gan Hui Tin, Joseph He Jun (Lim How Teck attended 1 meeting by invitation) | Attended 3 out of 3 meetings as member before resigning on 15/11/19 |
Table 2: Remuneration committee composition between FY2012 and FY2020[43]
REC’s disclosure of the breakdown in remuneration of individual directors is also arguably not in compliance with the SCCG as it shows percentage breakdown in three components of “fees”, “salary” and “others”, with no further breakdown of the “others” component. CHS was not paid “fees”.
Between 2013 and 2016, up to 86% of CHS’s total remuneration was disclosed under “others”. The remuneration sections of the company’s corporate governance statement say that his remuneration includes “a variable bonus as well as share option elements”, which would have been disclosed under “others”. He is not eligible to participate in the performance share plan. From the directors’ reports in the company’s annual reports since 2012, no additional options were granted to CHS after FY2012. In other words, the remuneration under “others” from 2013 to 2016 includes a variable bonus but not share-based remuneration. The company did not disclose whether there are benefits that are included under “others”. However, in response to questions from shareholders for the 2020 AGM, REC disclosed that none of the directors were paid benefits and that the “others” remuneration for CHS refers to his incentive bonus in his service agreement.[44] It is unclear whether is there any cap on his incentive bonus.
The company did not disclose what CHS’s variable bonus is linked to but it appears to be closely linked to the annual profits of the company. In FY2012, when REC reported a huge loss of S$66.3 million, CHS received remuneration in the range of S$750,001 to S$1 million. The following year, his remuneration increased by more than 100% as the company’s profit recovered to S$26.7 million. However, profit was still well below FY2010 and FY2011. In FY2014, his remuneration more than doubled again to the range of S$5 million to S$6 million as the company’s profit increased to S$55.4 million. However, the profit in FY2014 was only slightly higher than FY2010. In FY2020, his remuneration – which was 100% in salary – increased to the range of S$1,000,000 to S$1,500,000, compared to S$850,000 to S$900,000 in the previous year, even as the net profit attributable to shareholders of more than S$40 million in FY2019 turned into a net loss of more than S$16 million.
Unfortunately, there is no transparency about any profit-sharing formula and what measure of profit is used. REC is of course far from alone in being non-transparent about remuneration amounts and policies. It is unfortunate that our regulators are not doing more to open up this Pandora’s box as major shareholders who are involved in management commonly receive outsized remuneration due to generous profit-sharing percentages, rather than distribute dividends which all shareholders are entitled to.
CHS’s remuneration increased considerably over a period when cash flow from operations deteriorated considerably and the share price continued to fall. Between FY2013 and FY2016 when CHS was receiving a variable bonus, shareholders only received dividend of 1 cent per share for two of those years, and none for the other two years.
In FY2015, the company said that the RC had reviewed CHS’s remuneration package with the assistance of Hay Group, an external management consulting company. Following the review, the RC proposed a revision of the CEO’s remuneration package which was approved by the REC board.[45] It is interesting that CHS’s fixed salary appears to have increased in FY2016, following the assistance received from Hay Group. Setting remuneration in founder- or family-controlled companies where major shareholders or their family members are involved in management is challenging, and remuneration consultants may be ill-equipped to recommend appropriate remuneration policies and packages in such situations.
In the case of the ED and Deputy CEO Chew Kok Chor, who is unrelated to CHS, he received between S$500,001 and S$750,000 between FY2012 and FY2016, and between S$250,001 and S$500,000 in FY2017. He resigned from the company on 2 January 2018.[46]
Remuneration of family members
In FY 2013, CHS’s wife, Doris Chung joined the business. This was followed by his eldest son, Chew Han Wei, in FY 2016 and his second son, Chew Han Qiang, in FY 2018. In the corporate governance statement, one of the matters reserved for the board is “endorsing the appointment of key personnel”, while the appointment of key personnel does not fall within the stated functions of the NC and RC. “Endorsing” is not the same as approving. It does not appear that the board and board committees have much oversight over the appointment of CHS’s family members to the business.
The remuneration received by CHS’s spouse and sons for their roles in the group is summarised in Table 3. The amounts have increased over the years but declined in FY2020. While the disclosure of remuneration amounts in bands is compliant with the SCCG, there is no transparency regarding why the remuneration amounts changed.
| Financial year | Doris Chung
(spouse) |
Chew Han Wei (eldest son) | Chew Han Qiang (second son) |
| 2012 | – | – | – |
| 2013 | Between S$100,000 to S$150,000 | – | – |
| 2014 | Between S$250,000 to S$300,000 | – | – |
| 2015 | Between S$250,000 to S$300,000 | – | – |
| 2016 | Between S$250,001 to S$300,000 | Between S$50,001 to S$100,000 | – |
| 2017 | Between S$250,001 to S$300,000 | Between S$150,001 to S$200,000 | – |
| 2018 | Between S$250,001 to S$300,000 | Between S$200,001 to S$250,000 | Between S$50,001 to S$100,000 |
| 2019 | Between S$400,000 to S$450,000 | Between S$200,000 to S$250,000 | Between S$150,000 to S$200,000 |
| 2020 | Between S$350,001 to S$400,000 | Between S$151,000 to S$200,000 | Between S$100,001 to S$150,000 |
Table 3: Remuneration of Chew’s spouse and sons between FY2013 and FY2020[47]
Remuneration of key management personnel
Although the SCCG recommends that the remuneration of at least the top five key management personnel (who are not directors or the CEO) be disclosed – including the names, amounts and breakdown of remuneration in bands no wider than S$250,000,[48] this was not done because REC’s board is of the opinion that such a disclosure “would compromise confidentiality and may affect the retention of competent personnel”.[49]
Key Takeaways
In this article, we can see that the IDs and NINEDs on the REC board lacked experience in the education sector, which raises questions as to whether they are equipped to oversee an education business and to sufficiently understand issues related to quality of education. They also lack experience in the property sector which REC has diversified into. CHS and his family members also appear to lack experience in the property sector. Can a healthcare company be successful in the long term if none of the directors or management have significant experience in that sector? Or a technology company with no one who has deep experience in the technology industry?
The board also appears to have little oversight over the appointment of family members of CHS into the business, which raises questions as to whether they possess the necessary competencies and experience and are the best people to bring the company forward.
We also see in this article that REC is not transparent about the remuneration of its directors and changes in remuneration amounts for the founder and his family members. The close involvement of CHS in the RC over the years, either as a member or as participant by invitation, raises questions about his influence over determination of his remuneration and that of his family members – notwithstanding the disclosure by REC about policies on handling conflicts of interest.
In the next article, I will look at the financial and share price performance of REC and the changes its business. Harder lessons lie ahead.
Endnotes
[1] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
[2] Raffles Education Corporation Limited. (n.d.). Annual Report 2012. Retrieved from https://raffles.education/images/Investor/AnnualReport/Raffles-AR2012.pdf
[3] Ibid.
[4] Tan, K. (2010). Giving Back to Alma Mater: NBS Alumnus Henry Tan Song Kok. Retrieved from http://enewsletter.ntu.edu.sg/(X(1)S(i0gz13qnyqvhilai3qoc1txq))/NBSAlumni/Nov2010/Pages/AlumniUpdates2.aspx?AspxAutoDetectCookieSupport=1
[5] Ibid.
[6] Raffles Education Corporation Limited. (2018, March 6). Change – Announcement of Cessation: Resignation of Lead Independent Director, Mr Henry Tan Song Kok. Retrieved from https://links.sgx.com/FileOpen/HT-Past-and-Present-Directorships-APPENDIX-A.ashx?App=Announcement&FileID=491878
[7] Raffles Education Corporation Limited. (n.d.). Annual Report 2012. Retrieved from https://raffles.education/images/Investor/AnnualReport/Raffles-AR2012.pdf
[8] Ibid.
[9] Ibid.
[10] Raffles Education Corporation Limited. (n.d.). Annual Report 2017. Retrieved from https://raffles.education/images/Investor/AnnualReport/Raffles-AR2017.pdf
[12] Raffles Education Corporation Limited. (n.d.). Annual Report 2012. Retrieved from https://raffles.education/images/Investor/AnnualReport/Raffles-AR2012.pdf
[13] Raffles Education Corporation Limited. (2017, November 30). Announcement of cessation: Resignation of independent director, Mr Lim Tien Lock, Christopher. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/ZL75UFJ2LZBKMOGL/c9ae20227761760dbfbebb6eba22ac919097c6d0cb4bc0e6dcf750db54f58fa1
[14] Raffles Education Corporation Limited. (2017, December 19). Announcement of cessation: Resignation of executive director, Mr Chew Kok Chor. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/DH0X7EXUZGBJ2FXE/3ba618d2e2441cb02db7c8ffe5d0173caf459cff8e176fa765253c77012bfba9
[15] Raffles Education Corporation Limited. (2018, March 6). Announcement of cessation: Resignation of lead independent director, Mr Henry Tan Song Kok. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/OTACKO4LT7SYMK8U/f9ccf7bab5976f0d0559b017260c22aabac585146a786a7cf410bb736695e38c
[16] Heliconia Capital Management Pte Ltd. (n.d.). About Us. Retrieved from http://www.heliconiacapital.com/Aboutus.aspx
[17] Raffles Education Corporation Limited. (2018, March 6). Announcement of appointment: Appointment of independent non-executive director. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/W9ETWLZ6RW6IRWAP/c909fe45c52ac7079ef9728c371b994e9f410b7fd34c7a9b2b1639f80e446dab
[18] Swissco Holdings Limited. (2017, May 11). Resignation of lead independent director. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/VHUDHBX1P4EC4IJD/473917a3ed598a616a0940ec707456ed2a063b235454b7df1417ea65c7fd80f4
[19] Raffles Education Corporation Limited. (2018, March 6). Announcement of appointment: Appointment of independent non-executive director. Retrieved from https://links.sgx.com/FileOpen/LHT-Past-and-Present-Directorships-APPENDIX-A.ashx?App=Announcement&FileID=491881
[20] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
[21] Raffles Education Corporation Limited. (2018, April 25). Announcement of appointment: Appointment of independent non-executive director. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/0STMMWL219XC1KKD/d143522e6a24048782aada70c1232836a3ddc2fe78b3cb47d141e9f4dfec287f
[22] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
[23] Raffles Education Corporation Limited. (2018, October 29). Announcement of cessation: Retirement of director. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/06LEBEU25W9KMDPF/fbaf474064fb4f330f30b9d2216c350ca2caf82aa561c146744c22e00df554b1
[24] Raffles Education Corporation Limited. (2018, November 6). Announcement of appointment: Announcement of non-independent non-executive director. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/1D1UIDDMPFDJ2UZ7/19fb690169eef0f1317b8c7eabae4c4da0c8251b05833dc91aad3dcb20b3a99e
[25] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
[26] Raffles Education Corporation Limited. (2018, November 6). Announcement of appointment: Announcement of non-independent non-executive director. Retrieved from Retrieved from https://links.sgx.com/FileOpen/Directorships%20of%20Joseph%20He%20Jun%20Appendix%20B.ashx?App=Announcement&FileID=532613
[27] Raffles Education Corporation Limited. (2019, November 17). Announcement of appointment: Appointment of non-independent, non-executive director. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/FUKYYNL415Q391D1/30603075597ba38a4a8a372eaedca9e5a4fe69cd8c160a130963969ea733de73
[28] Raffles Education Corporation Limited. (n.d.). Corporate information – board of directors. Retrieved from https://raffles.education/Corporate_Info_BOD.html
[29] Raffles Education Corporation Limited. (n.d.). Annual Report 2018. Retrieved from https://raffles.education/images/Investor/AnnualReport/Raffles-AR2018.pdf
[30] Raffles Education Corporation Limited. (n.d.). Annual Report 2020. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC-AR2020.pdf
[31] Raffles Education Corporation Limited. (2021, July 1). Announcement of cessation: Announcement of cessation of independent director. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/TLKKNA60Q39JPI91/b1ebfcb50a07dad7e0f6d27661bbb60c389dc024b7736d5bb447943b6d99e064
[32] Raffles Education Corporation Limited. (2021, July 1). Announcement of appointment: Appointment of independent director and changes to the board committees. Retrieved from https://links.sgx.com/1.0.0/corporate-announcements/3D3XD04DJOMD6JUU/63d4a720786b90ee138787b5d476d7810bd93199d370717ac4a763741fc09975
[34] Raffles Education Corporation Limited. (2019, November 15). Changes in the composition of the board of directors and committees of the board. Retrieved from https://links.sgx.com/FileOpen/REC-%20Changes%20in%20the%20Board%20and%20the%20Committees%20of%20the%20Board%20-15%20Nov%202019.ashx?App=Announcement&FileID=586431
[35] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
[36] Raffles Education Corporation Limited. (n.d.). FY2012-2019 Annual Reports. Retrieved from https://raffles.education/InvestorRelations.html
[37] Ibid.
[38] Ibid.
[39] Raffles Education Corporation Limited. (n.d.). Annual Report 2017. Retrieved from https://raffles.education/images/Investor/AnnualReport/Raffles-AR2017.pdf
[40] Raffles Education Corporation Limited. (n.d.). Annual Report 2018. Retrieved from https://raffles.education/images/Investor/AnnualReport/Raffles-AR2018.pdf
[41] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
[42] Raffles Education Corporation Limited. (2019, November 15). Changes in the composition of the board of directors and committees of the board. Retrieved from https://links.sgx.com/FileOpen/REC-%20Changes%20in%20the%20Board%20and%20the%20Committees%20of%20the%20Board%20-15%20Nov%202019.ashx?App=Announcement&FileID=586431
[43] Ibid.
[44] Raffles Education Corporation Limited. (2020, October 26). Annual General Meeting for financial year end 30 June 2020 – Response to substantial and relevant questions from shareholders. Retrieved from https://links.sgx.com/FileOpen/REC%20-%20AGM%2030%20Oct%202020%20-%20Response%20to%20Shareholders%20Queries%20-%2026%20Oct%202020.ashx?App=Announcement&FileID=636420
[45] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
[46] Raffles Education Corporation Limited. (n.d.). FY2012-2019 Annual Reports. Retrieved from https://raffles.education/InvestorRelations.html
[47] Ibid.
[48] Singapore Institute of Directors. (n.d.). Disclosure on remuneration. Retrieved from https://www.eguide.sid.org.sg/index.php/singapore-code-of-corporate-governance/practice-guidance/disclosure-on-remuneration
[49] Raffles Education Corporation Limited. (n.d.). Annual Report 2019. Retrieved from https://raffles.education/images/Investor/AnnualReport/REC_AR2019.pdf
