2Futures

Code of conduct and practice

1. Scope and Objectives

This Code of Conduct and Practice (the “Code”) sets out the minimum standards of professional conduct and client care applicable to the companies of the 2Futures group listed in Annex A (each individually referred to as the “Company”) in carrying out its activities as a registered real estate agent.

The Code is adopted pursuant to the Second Schedule to the Real Estate Agent Authority (Registration and Fees) Regulations 2026, made under the Real Estate Agent Authority Act 2020.

The Code complements the Act and serves as a reference point for discipline. Any material or persistent breach may result in disciplinary action by the Real Estate Agent Authority (the “Authority”), which action shall be proportionate to the nature and severity of the breach and may include suspension or revocation of the Company’s registration.

2. Professional Competence

The Company shall:

  • exercise appropriate skill, care, diligence and competence in all real estate agency work;
  • maintain sound knowledge of the Real Estate Agent Authority Act 2020, regulations made under the Act and other applicable laws; and
  • undertake such continuing education as may be required by the Authority.

The Company shall take reasonable steps to ensure that persons carrying out real estate agency work on its behalf have the appropriate knowledge and competence to perform their functions.

3. Professional Conduct

In conducting its activities, the Company shall:

  • act in good faith;
  • comply with its fiduciary obligations;
  • deal fairly with all parties;
  • not mislead clients or provide false information;
  • not withhold material facts from clients;
  • refrain from any conduct likely to bring the real estate industry into disrepute; and
  • ensure that all advertisements are fair, accurate and not misleading.

All advertisements issued by or on behalf of the Company shall display the Company’s full name and its Real Estate Agent Authority registration number.

4. Reporting Misconduct

The Company shall report to the Authority:

  • any reasonable suspicion of misconduct or unsatisfactory conduct by another real estate agent, within 10 working days of becoming aware of such suspicion; and
  • immediately, any suspected unlicensed real estate agency practice.

The Company shall not misuse the complaints or disciplinary process against another real estate agent.

Any employee who becomes aware of conduct which may require reporting under this section shall promptly escalate the matter internally to the person responsible for Legal and/or Compliance.

5. Duties of the Company as Real Estate Agent

The Company shall:

  • prominently display this Code at its place or places of business and on its website;
  • ensure proper supervision and management of the work performed by its employees and contractors;
  • maintain the confidentiality of client’s personal information, except where disclosure is required by law, consented to by the client in writing, or reasonably necessary for the Company’s legitimate business activities, including disclosure to its professional advisers, insurers, affiliated companies within the 2Futures group, or regulatory authorities, provided that in each case such disclosure is made in compliance with applicable data protection legislation; and
  • notify the Authority of any material change in the particulars provided by the Company upon registration, within 14 working days of such change.

Employees and contractors carrying out real estate agency activities on behalf of the Company shall act under the Company’s appropriate supervision and in accordance with this Code.

6. Client and Customer Care

The Company shall:

  • act in the best interests of its client, subject to the Company’s obligations under applicable law and its reasonable commercial constraints;
  • communicate regularly with its client;
  • avoid subjecting its client to undue pressure;
  • advise its client to seek legal or technical advice before signing any contractual document;
  • disclose any defects and significant risks relating to a real estate transaction which are actually known to the Company at the relevant time, provided that the Company shall not be required to undertake independent technical or structural investigations;
  • refrain from imposing conditions in an agency agreement that are not reasonably necessary to protect the Company’s legitimate business interests; and
  • avoid conflicts of interest and, where the Company acts for or receives commissions from more than one party in the same transaction, disclose such interest in writing to all affected parties and obtain their prior written consent.

7. Record Keeping and Transparency

The Company shall ensure that:

  • all offers are submitted to its clients in writing;
  • copies of all written offers are retained for a minimum period of 36 months;
  • commission structures are clearly explained before any agreement is signed;
  • marketing expenses are clearly explained before any agreement is signed;
  • contractual obligations are clearly explained before any agreement is signed; and
  • all advertising and marketing activities conform to the selling client’s instructions.

Appropriate records shall be maintained to demonstrate compliance with these requirements.

8. Complaints and Dispute Resolution

The Company shall maintain a written in-house complaints procedure which is found in Annex B.

The Company shall:

  • inform clients of its in-house complaints procedure;
  • prominently display the complaints procedure at its office;
  • inform clients of their right to access the Authority’s complaints process directly;
  • notify the Authority of any formal written complaint made against the Company within 10 working days of receipt; and
  • notify the Authority of the outcome of such formal written complaint within 10 working days.

All complaints shall be handled fairly and in accordance with the Company’s written complaints procedure.

9. Compliance with this Code

This Code applies to the Company’s real estate agency activities and shall be communicated to all relevant employees and contractors.

Employees and contractors shall promptly refer any uncertainty regarding the application of this Code to the appropriate person responsible for Legal and/or Compliance.

The Company shall take reasonable steps to ensure that its real estate agency activities are conducted in accordance with this Code at all times.

Date: 1 October 2026

Annex A – the 2Futures companies registered as real estate agent under the Act are:

No. Company Name Real Estate Agent Authority Registration No.
1. Two Futures Realty Ltd
2. AMTF Residences Ltd
3. New Futures Ltd
4. Serenity Futures Ltd
5. New Casuarina Ltd
6. Pereybere Futures Ltd
7. LP Residences Ltd
8. Coastwise Property Ltd
9. TLMV Property Development Ltd
10. Ki Signature Villas Ltd
11. Yellow Futures Ltd

Annex B – 2Futures In-House Complaints Procedure

1. Purpose

This In-House Complaints Procedure (the “Procedure”) establishes the process for receiving, reviewing and resolving complaints relating to the real estate agency activities of the Company.

This Procedure has been established in accordance with the Code of Conduct and Practice contained in the Second Schedule to the Real Estate Agent Authority (Registration and Fees) Regulations 2026.

The Company is committed to handling complaints fairly, objectively, professionally and within a reasonable timeframe.

2. Who May Make a Complaint

Any client or other person who has dealt directly with the Company in connection with a specific real estate agency transaction or service may submit a complaint concerning the services or conduct of the Company or any employee, representative or contractor acting on its behalf.

3. How to Make a Complaint

Complaints should be submitted in writing either by email to: ap@2futures.com, or delivered by registered post with advice of delivery to:

[Company Name] Ltd
c/o the Chief Legal Officer
3rd Floor MCBQ iQ
Royal Road
Pointe aux Canonniers

A complaint should include:

  • the subject Complaint under the Real Estate Agent Authority Act;
  • the complainant's full name and contact details (postal address, mobile phone number, email address);
  • the project name and unit number;
  • the transaction concerned (CRP/VEFA/SCIA);
  • the full company name of the real estate agency involved of the transaction and the full name of the sales agent of the real estate agency involved;
  • a detailed description of the complaint;
  • relevant dates and persons involved;
  • any supporting documents or correspondence; and
  • the outcome or resolution expected.

Where a complaint is initially made verbally, the Company shall require that the complaint be confirmed in writing before commencing a formal investigation, where this is reasonably necessary to properly investigate it.

Where a complaint is incomplete, the Company may require further details to be provided in writing before commencing a formal investigation, where this is reasonably necessary to properly investigate it.

4. Acknowledgement and Registration

Upon receipt, the complaint shall be:

  • recorded in the Company's Complaints Register;
  • assigned to an appropriate person for review; and
  • acknowledged to the complainant within 5 working days, where practicable.

The acknowledgement shall confirm that the complaint has been received.

5. Review and Investigation

The person responsible for handling the complaint shall review the matter fairly and objectively.

The investigation may include:

  • reviewing the relevant transaction file and correspondence;
  • obtaining information from the employee, representative or contractor concerned;
  • reviewing agreements, advertisements, offers or other relevant documents;
  • requesting additional information from the complainant; and
  • consulting the Company's Legal and/or Compliance function where appropriate.

A person who is directly the subject of a complaint should not, where reasonably practicable, be solely responsible for determining its outcome.

The Company’s employees and contractors shall cooperate fully with the investigation of a complaint. The complainant is encouraged to cooperate with the investigation.

6. Response to the Complainant

The Company shall endeavour to provide a response to the complainant within 10 working days of receiving all information reasonably required to investigate the complaint.

Where the complaint cannot reasonably be resolved within that period, the complainant shall be informed of:

  • the status of the complaint;
  • the reason additional time is required; and
  • the expected timeframe for a final response.

The Company's final response shall, where appropriate:

  • communicate the outcome of the Company's review;
  • explain any corrective or remedial action to be taken; and
  • inform the complainant of his or her right to approach the Authority.

7. Notification to the Authority

In accordance with the applicable Code of Conduct and Practice, the Company shall:

  • notify the Real Estate Agent Authority of any formal written complaint made against the Company within 10 working days of receipt of the written complaint; and
  • notify the Authority of the outcome of the complaint within 10 working days of the final determination or resolution of the complaint.

All notifications to the Authority shall be coordinated through the Company's Legal and/or Compliance function or such other person designated by the Company.

8. Right to Approach the Authority

The Procedure does not restrict a complainant's right to make a complaint directly to the Authority.

A complainant is not required to exhaust Procedure before approaching the Authority.

Information concerning the Authority and its complaints process may be obtained from the Authority.

9. Confidentiality

Complaints and information obtained during their investigation shall be treated confidentially and disclosed only to persons who reasonably require the information for the purpose of investigating or resolving the complaint, to the Real Estate Agent Authority as required under Section 7 of this Procedure, or where disclosure is otherwise required or permitted by law.

10. Complaints Register

The Company shall maintain a complaints register (the “Complaints Register”) containing, at a minimum:

  • the date the complaint was received;
  • the name of the complainant;
  • the property or transaction concerned;
  • a brief description of the complaint;
  • the person responsible for handling the complaint;
  • material steps taken to investigate the complaint;
  • the outcome and date of resolution;
  • the date on which the complaint was notified to the Authority; and
  • the date on which the outcome was notified to the Authority.

Supporting documentation and correspondence relating to the complaint shall be retained with the relevant complaint record for a minimum period of 5 years from the date of resolution of the complaint.

11. Corrective Action

Where a complaint identifies a deficiency in the Company's practices, the Company shall consider whether corrective action is required.

Corrective action may include:

  • correcting inaccurate information;
  • addressing a client service issue;
  • amending an advertisement or marketing material;
  • providing additional guidance or training to employees;
  • reviewing an internal procedure; or
  • taking appropriate disciplinary or other action where misconduct is established.

The Company shall also consider whether the issue identified may affect other clients or transactions and, where appropriate, take broader corrective action.

12. Availability of this Procedure

Clients shall be informed of the existence of this Procedure.

This Procedure shall be displayed at the Company's office and website, in accordance with the Code of Conduct and Practice.

A copy shall also be made available to any client upon request.

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