Whistle-Blowing Policy

1. Purpose
   1. WAKOMAS Chemical Sdn Bhd means and includes its subsidiaries and related companies, present or in the future, and shall hereafter be referred to as “the Group”. A list of the companies in the Group is annexed hereto as “Annexure A” and may be updated from time to time.
   2. The Group shall conduct its business with honesty, integrity, transparency, and respecting the laws, cultures, dignity and rights of individuals in all countries where it operates. All of the Group’s:
      1. Full time, probationary, contract and temporary employees including Directors (“Employees”); and
      2. Ongoing or potential customers, suppliers, bankers, service providers, contractors, and sub-contractors of any tier of the Group (“Business Associates”) are expected to act in accordance with the Group’s corporate values and ethics.
2. Scope
   1. The Group has adopted this Whistle-blowing Policy (“Policy”) to provide an avenue for the Employees, Business Associates, and public members to raise genuine concerns of any wrongdoing or improper conduct involving the Group and its Employees. It will also protect the reporter who reports such allegations.
   2. Where the context or construction requires, all words applied in plural will be deemed to include the singular and vice versa; the masculine will include the feminine and neuter, and vice versa; and present tense will consist of the past and future tense vice versa.
3. Guiding Principles
   1. Types of Reportable Misconduct
      1. This Policy designed to facilitate the disclosure of any misconduct or criminal offence through an internal channel. Under the Group’s Employee Handbook (“EH”), “misconduct” is taken to mean any improper behaviour, act, or conduct related to the Employee’s duty or work, which is inconsistent with the due performance of his obligations as an Employee. In addition, the Group also regards that misconduct shall include a breach of discipline, articles in the EH, rules, policies, procedures, circulars, statements and SOPs implemented by the Management. The following list, which is not exhaustive, shall constitute as “Reportable Misconduct” under this Policy:
         1. Fraud, misappropriation of funds or assets;
         2. Bribery, corruption or blackmail;
         3. Violation of the Group’s EH, procedures or policies;
         4. Improper or unethical conduct or behaviour;
         5. Conflict of interest;
         6. Theft or embezzlement of fund or assets;
         7. Abuse of power or position;
         8. Breach of confidentiality;
         9. Criminal breach of trust;
         10. Failure to comply with any legal obligations or breach of internal control;
         11. Danger to health and safety of any Employee of the Group or any other individual;
         12. Sexual harassment.
   2. Protection for Whistle-blower
      1. The Group is committed to ensuring confidentiality in respect of all matters raised under this Policy.
      2. Confidentiality

         The confidentiality of the whistle-blower’s identity will be ensured and protected, to the extent reasonably practicable, unless otherwise required by law. The Group assures that all reports will be treated in the strictest confidence and will be promptly investigated.

      3. Assurance against retaliation and immunity from disciplinary action

         This Policy assures that the whistle-blower, if an Employee, shall be protected against retaliation and enjoy immunity from any civil or criminal liability or any liability by way of the administrative process, including disciplinary action from the whistle-blower’s immediate supervisor or HOD or any other person exercising power or authority over the whistle-blower in his employment.

   3. Reporting with Reasonable Belief
      1. The Group expects the whistle-blower to report genuine concerns about unethical behaviour, malpractices, illegal acts or failure to comply with regulatory requirements without fear of reprisal. However, the whistle-blower should make disclosure based on a reasonable belief that any person has engaged, is engaging or is preparing to engage in improper conduct, provided that any written law does not explicitly prohibit such disclosure.
      2. However, there are instances where whistle-blower protection will be revoked; for example, in such circumstances as the whistle-blower himself has participated in the improper conduct disclosed, or the disclosure made is frivolous or vexatious, or the whistle-blower wilfully disclosed that he knew or believed to be false.
      3. Malicious and false allegations reported will be viewed seriously and treated as gross misconduct. If proven, it may lead to dismissal for Employees. The Group will also take appropriate action against the reporter concerned, including legal action, where applicable.
      4. If, however, a report is made in good faith, and a subsequent investigation proves it to be untrue, the whistle-blower will still be eligible for protection under this Policy.
   4. Whistle-blowing Channel
      1. The WHISTLE-BLOWER REPORT FORM, is annexed hereto as “Annexure B” and may be updated from time to time, can be downloaded from the Group’s website at www.wakomas.com.my. The report can be submitted via email or post (marked “Strictly Confidential”) and directed to the Head of Business Improvement. The whistle-blower shall disclose his identity in the form attached.
      2. The channel of reporting is as follows:

         Title	:	Head of Business Improvement
         E-mail	:	compliance@wakomas.com.my
         Telephone	:	+603 7492 2611
         Address	:	E-7-08, Capital 5, Oasis Square, No. 2A Jalan PJU 1A/7A, Ara Damansara, 47301, Petaling Jaya, Selangor Darul Ehsan

      3. Upon receiving a report, the Business Improvement HOD shall act promptly to investigate and resolve the issue.
      4. The whistle-blower shall be informed of the progress and outcome of the investigation.
   5. Revisions
      1. This Policy shall be updated, amended, or revised from time to time to ensure its adequacy in implementation and enforcement.
4. References
   1. Whistleblower Protection Act 2010