Wrongful Conduct - Daniel James Tai Hann, Director of UrbanRx Compounding Pharmacy (The Pharmacy Inc.)
Acknowledgement letters (Suit HC/S 164/2018) on wrongful conduct to Amber
[ANNEX B - Form of Statutory Declaration for 4th Defendant]
I, Daniel James Tai Hann (Malaysia Passport No.: K34xxxxxx) of Sibu, Sarawak, Malaysia, do solemnly and sincerely declare as follows:
1. I am a director and shareholder of Urbanrx Compounding Pharmacy Pte Ltd ("Urbanrx"). The other director of Urbanrx is Priscilla Lim Suk Ling (NRIC No.: S85xxxxxx) ("Priscilla").
2. Priscilla, Urbanrx and I are defendants in HC/S 164/2018 (the "Suit") commenced by Amber Compounding Pharmacy Pte Ltd and Amber Laboratories Pte Ltd ("Amber").
3. I understand that in its Statement of Claim (Amendment No. 2) (the "SOC") filed in the Suit, Amber has claimed that certain material (set out at paragraph 5 of the SOC) are its confidential information (the "Confidential Information"). I confirm that I will not contest this claim of the confidential nature of the documents.
4. I confirm that I do not have the Confidential Information in my possession, and am not using any of the said Confidential Information (whether by myself, agents, servants or otherwise).
5. I am also aware that Priscilla and Urbanrx will not be contesting the claim of copying and breach of confidence by Amber in the Suit.
6. In the premises, I am disappointed by and regret the wrongful conduct of Priscilla and Urbanrx. As a director of Urbanrx, in line with my legal duties as a director, I will undertake best endeavours to ensure that Urbanrx (including staff) complies with orders made by the Court in the Suit.
SWORN by the abovenamed 
Daniel James Tai Hann
on this 15th day of September 2020
at Sibu, Sarawak, Malaysia
Before me
Wrongful Conduct - Tan Bo Chuan MD, husband of Priscilla Lim Suk Ling
Form of Statutory Declaration for 6th Defendant
I, Tan Bo Chuan (NRIC No.: S84xxxxxx) of Singapore, do solemnly and sincerely declare as follows:
1. I am the husband of Priscilla Lim Suk Ling (NRIC No.: S85xxxxxx) ("Priscilla"), who is a director and shareholder of Urbanrx Compounding Pharmacy Pte Ltd ("Urbanrx")
2. Priscilla, Urbanrx and I are denfendants in HC/S 164/2018 (the "Suit") commenced by Amber Compounding Pharmacy Pte Ltd and Amber Laboratories Pte Ltd ("Amber").
3. I understand that in its Statement of Claim (Amendment No. 2) (the "SOC") filed in the Suit, Amber has claimed that certain material (set out at paragraph 5 of the SOC) are its confidential information (the "Confidential Information"). I confirm that I will not contest this claim of the confidential nature of the documents.
4. I confirm that I do not have the Confidential Information in my possession, and am not using any of the said Confidential Information (whether by myself, agents, servants or otherwise). I understand that the Confidential Information was found on a laptop purchased by me for the use of the family, which Priscilla had used.
5. I am also aware that Priscilla and Urbanrx will not be contesting the claim of copying and breach of confidence by Amber in the Suit. In the premises, I am disappointed by and regret any wrongful conduct of Priscilla and Urbanrx and that Confidential Information was found on the device referred to above.
AFFIRMED/SWORN by the abovenamed 
TAN BO CHUAN
on this 16th day of September 2020
at Singapore
Before me
Apology for Wrongful Conduct by Muhammad ‘Ainul Yaqien bin Mohamed Zin, ex-employee
Form of Statutory Declaration of 3rd Defendant
I, Muhammad 'Ainul Yaqien bin Mohamed Zin (NRIC No.: S90xxxxxx) of Singapore, do solemnly and sincerely declare as follows:
1. I was an ex-employee of Amber Laboratories Pte Ltd ("Amber") before I joined Urbanrx Compounding Pharmacy Pte Ltd ("Urbanrx").
2. I am aware that Amber has commenced HC/Suit 164/2018. 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.
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. I acknowledge that I had a Notebook (referred to at paragraph 54 of the SOC) and that the Notebook and its contents belonged to Amber. I acknowledge that I should not have retained the Notebook upon my departure from Amber. I confirm that I have destroyed the said Notebook, and no longer have it in my possession.
4. On 16 June 2017, the day before my resignation from Amber, I took a photo of a page of the Notebook and sent it to a client of Amber, Imagene Labs. This I should not have done without the consent of the management of Amber.
5. I unconditionally and unreservedly apologise for my actions above, which i admit were a breach of my employment contract with Amber.
AFFIRMED by the abovenamed 
Muhammad 'Ainul Yaqien bin Mohamed Zin
on this 16th day of September 2020
at Singapore
Before me
Apology for Wrongful Conduct by Cheryl Tee I-Lin, ex-employee
Letter of Apology of Cheryl Tee I-Lin
Amber Compounding Pharmacy Pte Ltd
221 South Bridge Road
Singapore 058770
Amber Laboratories Pte Ltd
221 South Bridge Road
Singapore 058770
18 September 2020
Dear Sirs,
HC/S 164/2018
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.
SIGNED by
Name: Cheryl Tee I-Lin
NRIC No.: S85xxxxxx