Whistleblowing policy

In line with good corporate governance, it is important to the Company that suspected inappropriate behaviour or misconduct relating to fraud, corrupt practices, abuses or wrongdoing is reported and properly dealt with. The Company, therefore, encourages all reporting individuals to raise any concerns that they may have about the conduct involving the resources in the business or the way in which the business is run.

This policy sets out the way in which reporting individuals may raise any concerns that they have and how those concerns will be dealt with. It applies to all employees of the Company, full time and part-time employees on fixed-term contracts and others performing functions in relation to the Company, such as consultants, agents and contractors, are encouraged to use it. It is also available to use by any external third party or counterparty.

The Whistleblowing Policy has been developed as part of the Company’s Standard Operating Policies and Procedures and designed to conform to existing laws, regulations and guidelines imposed by the relevant authorities. This policy and procedure are not contractual and the Company reserves the right to amend it should it, in its sole discretion, elect to do so.

Principles For Handling Concerns
  • Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. Individuals should be watchful for illegal or unethical conduct and report anything of that nature that they become aware of.
  • Any matter raised under this procedure will be investigated thoroughly, promptly and confidentially, and the outcome of the investigation reported back to the worker who raised the issue. ·
  • No individual will be victimised for raising a matter under this policy. This means that the continued employment and opportunities for future promotion or training of the individual will not be prejudiced because he/she has raised a legitimate concern.
  • Victimisation of a worker for raising a qualified disclosure will be a disciplinary offence.
  • If misconduct is discovered as a result of any investigation under this procedure the Company’s disciplinary procedure will be used, in addition to any appropriate external measures.
  • Maliciously making a false allegation is a disciplinary offence.
  • An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, individuals should not agree to remain silent. 
Procedure for reporting fraud, corrupt practices and/or abuse

The following person and channels will be the point of contact for reporting any concern:

The Head of Asia Regional Risk and Compliance Committee and Head of Compliance Malaysia are responsible for centrally ensuring and overseeing the integrity, confidentiality, independence and effectiveness of this Policy, and any ensuing investigations.

Selvyn Soo, Head of Asia Regional Risk and Compliance Committee

Phone No. +603-9213 0606 ext 620

Mobile: +6012-282 3633

[email protected]

Michael S H Leong, Head of Compliance, Malaysia

Phone No. +603 9213 0606 ext 750

Mobile +6012-382 1435

[email protected]