Anti-Corruption & Whistleblowing

ANTI-CORRUPTION STATEMENT

Business growth is based principally on good governance and in line with this, it is necessary to build a culture of integrity and transparency within the organisation. The Company forbids any corruption activities to take place within all business conducts as it is detrimental to the communities it serves and the values practiced by the Company.

Corruptions refers to any offers, solicits, the giving or accepting of any improper payments such as donations, bribes, or anything of value that is offered in exchange for business favours, information, favourable treatment or similar.

This policy is applied to the Company as part of personnel management and it is expected for employees of the Company to observe and implement this policy. Non-compliance to this policy will result in disciplinary action whereby the punishment will be varied based on the severity of the violation. Periodic training on the contents of this policy will be provided to ensure that employees fully understand the concept of this policy and strictly follow it. This policy will also be communicated and made available to the public.

WHISTLEBLOWING PROCEDURE

The whistleblowing component of this policy aims to combat corruption by encouraging and facilitating transparency and integrity within the Company by supporting any and all stakeholders to disclose any improper conduct within the Company.

All disclosures made under this policy will be dealt with in a confidential manner.

Scope of Reporting

A person may make a disclosure of improper conduct to the Company based on his reasonable belief that any person has engaged, is engaging or is preparing to engage in improper conduct.

Improper conduct may include but are not limited to the following:

(a) Fraud or dishonesty;

(b) Breaches of policies, procedures and applicable laws and regulations;

(c) Bribery or corruption;

(d) Abuse of power;

(e) Conflict of interest;

(f) Theft or embezzlement;

(g) Insider trading;

(h) Misuse of Company’s information;

(i) Harassment, sexual harassment; and/or

(j) Intimidation.

Reporting Procedure

(a) All disclosures by the whistleblower should be made by sending an email address to [email protected]

(b) Disclosures made under this policy have to be submitted using the format of the form as provided in Appendix 1. (Click here to download)

(c) A whistleblower is required to have reasonable grounds for suspecting the reportable activity and subsequently, is responsible to ensure that the disclosure is made in good faith, free from malicious intent, and not for personal gains.

(d) Further action may be taken in probing for additional details as deemed necessary before the commencement of further investigations on the alleged wrongdoing party(ies).

Whistleblower Protection

(a) The whistleblower is encouraged to disclose his/her identity in order to enable the Company to accord the whistleblower the necessary protection under the Whistleblower Protection Act 2010 and to obtain more details on the allegation/report.

(b) The whistleblower, however, may choose to remain anonymous, although doing so may limit the ability for thorough investigation due to insufficient information. This policy provides assurance that the Company will protect the confidentiality of all allegations raised and the identity of the whistleblower at all times.

(c) The protection under this policy will only be accorded provided that the disclosure is made in good faith. Such protection is accorded even if the investigation later reveals that the Whistleblower is mistaken as to the facts as well as the rules and procedures involved.