WHISTLEBLOWING POLICY

1.0 OVERVIEW

  1. Elegant World (M) Sdn. Bhd. and its Group of Companies (“the Group”) are committed to conducting their business activities with integrity, high ethical standards and accountability.
  2. This Whistleblowing Policy (“Policy”) is developed to:- i) protect the values of integrity where the Group conducts its business activities; ii) establish a structured reporting channel and guidance for responding to any reports from Employees and Stakeholders regarding such potential violations or concerns; and iii) protect Whistleblower from reprisal and to safeguard the Whistleblower’s confidentiality.

2.0 SCOPE AND APPLICATION

  1. “Whistleblowing” is a deliberate, voluntary disclosure/reporting (supported with evidence/detailed information) of an individual or company by a person, who has privileged access to information based on an actual or suspected Improper Conduct (defined hereunder) within the Group.
  2. “Whistleblower” means any person who discloses information of Improper Conduct (as defined hereunder) in accordance with Policy.
  3. “Improper Conduct” means any conduct which if proved, constitutes a violation of ABC Policy or laws or concealment of either or both.
  4. This Policy applies to the Group’s Employees and Stakeholders with an employment or business relationship with the Group.
  5. This Policy does not apply to Employees’ grievances, which shall be dealt in accordance with Group Human Resource’s guidelines and policies.
  6. Any Whistleblower who intends to lodge any report of Improper Conduct must have reasonable grounds for believing in its existence and must undertake such reporting in good faith and for the best interest of the Group.
  7. The good faith element shall be deemed lacking if:- i) the person does not have personal knowledge or a factual basis for the report of Improper Conduct; or ii) the person knew or reasonably should have known that the reports are false, frivolous or vexatious; or iii) the report has been made with malicious intent, ulterior motive or for personal gain.

3.0 REPORTING PROCEDURE

  1. All reports shall be communicated in writing made through email (using the attached Appendix A: Whistleblowing Report”) to abc.compliance@elken.com. The report must provide full details of the Improper Conduct and where possible, with the supporting evidence/detailed information. Anonymous complaints will not be entertained.

4.0 WHISTLEBLOWER PROTECTION

  1. Whistleblower who reports in good faith will be protected from any adverse and detrimental treatment and will be accorded with confidentiality of identity protection, to the extent reasonably practicable.
  2. Any Whistleblowing not made in good faith and is found to be deliberately falsified with malicious intent will be subjected to appropriate disciplinary actions or legal repercussions, where appropriate.

5.0 SCREENING AND INVESTIGATION

  1. The Anti-Bribery & Anti-Corruption Committee (ABC) will screen and assess the Whistleblower’s disclosure to determine whether it constitutes an Improper Conduct or is excluded from the scope of this Policy. The Whistleblower may be required to provide additional information and clarifications if required.
  2. Based on the initial findings, ABC will decide on the next course of action whether to appoint authorised person(s) to carry out initial investigation, if required.
  3. After investigation, ABC will determine the merits of the Whistleblower’s disclosure and decides, including but not limited to the following:
    1. Commencing a full investigation by setting up Whistleblowing Governance Committee (WGC) in the event that the preliminary findings clearly indicate a basis for further investigation; or
    2. Reject the Whistleblower’s disclosure if the preliminary findings indicate no basis for further investigation; or
    3. Determine any other course of action which the ABC deems appropriate.
Please refer to Appendix B for Whistleblowing Procedures Flowchart.
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