1.0 POLICY STATEMENT
Contraves is committed to the highest standard of integrity, openness and accountability in the conduct of its businesses and operations. It aspires to conduct its a¬ffairs in an ethical, responsible and transparent manner.
1.1 OBJECTIVE OF THE POLICY
Recognising the abovementioned values, Contraves provides an avenue for all employees and directors of Contraves and external parties to disclose justified improper conduct within Contraves.
1.2 SCOPE OF THE POLICY
This policy is designed to facilitate employees and members of the public to disclose justified improper conduct (misconduct or criminal off¬ence) committed or about to be committed through the appropriate channel. Such misconduct or criminal offences include the following:
i. Fraud;
ii. Bribery;
iii. Abuse of Power;
iv. Conflict of Interest;
v. Theft or Embezzlement;
vi. Misuse of Company’s Property; and
vii. Non-Compliance with Procedure.
The above list is not exhaustive, and includes any act or omissions, which if proven, will constitute an act of misconduct under Contraves’ Code of Conduct and Business Ethics (COBE) or any criminal offence under relevant legislations in force.
This Whistleblowing Policy is not intended to address employee grievances. Employees can make grievance complaints to his/her immediate superior or HR.
1.3 APPLICABILITY OF THE POLICY
Our policy applies to every employee, director and officer of Contraves. Our contractors, agents, outsourced workers and business associates are required to always act consistently with applicable parts of this policy when dealing with, acting on behalf or in the name of Contraves. This policy also applies to members of the public, where relevant.
2.0 PROCEDURE IN MAKING A DISCLOSURE
Any person can voice their concern when they become aware of actual or potential wrongdoing committed by any Contraves employee, director or related third party by submitting a whistleblowing report using the channel below:
Email: governance@contraves.com.my
General Line: +6 03 8311 1000 (Mondays to Fridays excluding public holidays)
Contact Persons: Corporate Governance or Human Resources Department
Contactable Hours: Working days, 9:30 a.m. - 5:30 p.m. *
At minimum, the whistleblowing report must contain the following disclosures:
i. Description of the misconduct and how it was discovered;
ii. Identity of the person(s) committing the alleged wrongdoing; and
iii. Clear and unfabricated evidence in support of the allegation. (It is highly recommended to attach relevant documents, files, videos and/or photos with date and time as evidence to support the whistleblowing report).
3.0 ANONYMOUS WHISTLEBLOWER
Any employee or external parties who wish to report improper conduct may remain anonymous. However, the contact details (email address and contact number) are required in order for the Whistleblowing Committee to reach out to the whistleblower.
4.0 PROTECTION TO WHISTLEBLOWER
All information provided by the whistleblower shall be kept strictly confidential. A whistleblower will be accorded with protection of confidentiality of identity, to the extent reasonably practicable. In addition, an employee who whistleblows internally will also be protected against any adverse and detrimental actions for disclosing any improper conduct committed or about to be committed within Contraves, to the extent reasonably practicable, 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, and the rules and procedures involved.
5.0 NOTIFICATION
When you report a concern, you can expect that your report will be treated seriously, fairly and promptly. You may expect updates during and upon completion of our investigation, unless we take the view that disclosure may impede investigation.
Effective 1 November 2023
On behalf of CONTRAVES ADVANCED DEVICES SDN BHDCHIEF EXECUTIVE OFFICER