Letter of Apology of Cheryl Tee I-Lin
Amber Compounding Pharmacy Pte Ltd
221 South Bridge Road
Amber Laboratories Pte Ltd
221 South Bridge Road
18 September 2020
I, Cheryl Tee I-Lin (NRIC No.: S85xxxxxx), acknowledge and admit to the following:
1. I was an ex-employee of Amber Compounding Pharmacy Pte Ltd ("Amber") before I joined Complete Healthcare International ("CHI"), although I have since left CHI.
2. I am aware that Amber has commenced HC/Suit 164/2018 ("Suit 164"). In the Statement of Claim (Amendment No.2) (the "SOC"), I understand that Amber has claimed that various material amounts to confidential information (as set out in paragraph 5 of the SOC). I confirm that I will not contest this claim that the material at the said paragraph 5 is the confidential information of Amber. The other defendants include Priscilla Lim Suk Ling ("Priscilla") and Urbanrx Compounding Pharmacy Pte Ltd ("Urbanrx").
3. Insofar as this material is concerned, I confirm that I do not have in my possession such material any longer. I confirm that I will not use such material moving forward.
4. I further acknowledge that I had in my possession a hard disk which contained compounding worksheets belonging to Amber. This was created following an incident at Amber where a virus had infected certain devices on Amber's premises. I was tasked to back up information from these devices using a hard disk. I knew this hard disk and the data therein belonged to Amber, and that the hard disk contained confidential information belonging to Amber. I did not return this hard disk to Amber even after my employment ceased.
5. I admit that I had given this hard disk to Priscilla. The 1st Defendant returned the aforementioned hard disk to me at my work premises. As I knew that the hard disk contained Amber's compounding worksheets, I disposed of the hard disk in the CHI waste bin on the same day. I acknowledge that I should not have taken confidential information from Amber and given it to the 1st Defendant. I confirm that I have since disposed of the said hard disk, and no longer have it in my possession.
6. Additionally, I have attempted to have CHI switch suppliers from Amber to Urbanrx.
7. I deeply regret the various actions set out above, and undertake not to further carry out any such conduct or to use any confidential information belonging to Amber or in any way instigate suppliers and/or clients to choose Urbanrx over Amber.
8. I unconditionally and unreservedly apologise for my actions above, which I admit were a breach of my employment contract with Amber.
Name: Cheryl Tee I-Lin
NRIC No.: S85xxxxxx