1 INTRODUCTION

Whistleblowing Protection Policy (“WBP Policy”) is aimed to provide an avenue for all stakeholders of the Group, which refers to directors (both executive and non-executive), employees (e.g permanent, fix-term contract, part-time and interns) and external parties (e.g subcontractor, partners, business associates and any third parties who may have a business relationship with the Group) who voluntarily come forward to report or disclosed information on any wrongdoings, malpractice, improper conduct (as defined under the Whistleblower Protection Act 2020) and corruption related activities.

The disclosure should be made in “good faith” based on “honest and reasonable grounds at the material time” without necessitating hard evidence from the whistleblower. However, whistleblower can provide evidence if it is legally available through the course of his/her work. The whistleblower’s role is to report and not as an investigator.

2 POLICY STATEMENT

It is the Group’s policy that whistleblowing is a pivotal aspect of accountability and transparency mechanism to encourage all stakeholders to raise legitimate concerns in a responsible and effective manner about possible improprieties in matters of financial reporting, compliance and other related malpractices at the earliest opportunity, without fear of retaliation i.e. discrimination, harassment, penalised, victimisation or vengeance.

The Whistleblower Protection Act 2010 (“WPA”)

“An Act to combat corruption and other wrong doings by encouraging and facilitating disclosures of improper conduct in the public and private sector, to protect persons making those disclosures from detrimental action, to provide for the matters disclosed to be investigated and dealt with and to provide for other matters connected therewith.”

The provision of the WPA is to protect whistleblower against being penalised or dismissed by employers in raising legitimate concerns, which he/she reasonably believes may witness an improper conduct.

The WBP Policy is not designed to question financial and/or business decisions taken by the Group nor should it be used to raise any matters or doubts which have already been addressed under grievance, disciplinary or any other procedures. Once the said WBP Policy is implemented, it is reasonable to expect employees to directly or indirectly air their related complaints of wrongdoings or malpractice within the Group.

This policy applies to all stakeholders of the Group as mentioned earlier.

3 SCOPE OF POLICY

This policy is designed to :-

3.1 Ensure no whistleblower feel disadvantage in raising legitimate concerns.

3.2 Provide a transparent, confidential and fair process for dealing with the legitimate concerns.

3.3 Provide an avenue for stakeholders to raise legitimate concerns which could include :-

i. Financial malpractice or impropriety or fraud;

ii. Failure to comply with legal and regulatory obligations;

iii. Malpractice of health and safety or to the environment and the cover-up of any of these in the workplace;

iv. Criminal activity, negligence, breach of contract and law;

v. Bribery and corruption acts;

vi. Improper conduct or unethical behaviour;

vii. Any other malpractice matters which might cause financial and/or non- financial loss to the Group including demeaning the Group’s reputation

viii. Concealment of any or a combination of the above.

3.4 Ensure that stakeholders can raise legitimate concerns without fear of retribution. The legitimate concerns raised may be investigated separately where it might lead to the invocation of other disciplinary procedures. All legitimate concerns raised will be treated fairly.

4 SAFEGUARDS

4.1 Protection

i. Protection is offered to whistleblowers who disclose such legitimate concerns provided the disclosure is made :-

a. in good faith;

b. there is reasonable belief that the disclosure tends to show malpractice or impropriety and the disclosure is made to the appropriate person (see below).

. No protection will be offered to those who choose not to comply the WBP Policy.

4.2 Confidentiality and Anonymous Allegations

i. The Group will take every effort to maintain confidentiality of all such legitimate disclosures. The identity of the whistleblower making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. Identities will not be disclosed without prior approval as the investigation process may reveal the source of information including recording statement from the whistleblower to obtain substantial facts as part of the process or evidence required.

However, should the whistleblower choose to disclose his/her identity publicly, the Group is no longer obligated to maintain his/her confidentiality.

ii. Whistleblowers are encouraged to put their name to any allegations they make. Anonymous whistleblowers are encouraged to provide an email address or any contact information to facilitate proper investigation by the appointed investigating officer.

Additional factors taken into consideration to conduct the investigation will include :-

a. the seriousness of the issue raised;

b. the credibility of the concern; or

c. the likelihood of confirming the allegation from attributable sources.

4.3 Untrue Allegations

In making an allegation, the whistleblower needs to exercise due care to ensure the accuracy of the information.

i. If the allegation is made in good faith but not confirmed by subsequent investigation, no action will be taken against the individual who reported the concerns.

ii. If the allegation is found to be malicious or vexatious, the Investigation Panels have the right to take appropriate disciplinary action against the individual particularly if he/she is an employee who made such allegations.

5 DISCLOSURE CHANNELS AND PROCEDURE

5.1 Company Regulators

i, By email: mgt@llc-bhd.com

ii. By mail or hand-delivery with sealed enveloped marked “Strictly Private and Confidential”

LLC Berhad (Level 3),
No 19, 21, 23 & 25, Jalan Sri Hartamas 7,
Taman Sri Hartamas, 51200 Kuala Lumpur.

5.2 Concerns or information are better raised in writing via email by setting out the background and history of concern, subject/accuser name(s), date(s) and location(s) including documentary evidence where possible, and the reasons why they are particularly concerned about the situation. Whistleblowers are recommended to complete the Whistleblowing Report Form which is available on LLC’s website and directed to authorised personnel.

5.3 Appropriate actions as below maybe be taken based on the nature of the allegation :-

i. be resolved by agreed action without the need for investigation;

ii. be investigated internally;

iii. be referred to the relevant Government authorities;

iv. set up the Investigation Panels who are independent of the allegation to fully evaluate the facts of the pertinent concerns raised.

5.4 Whistleblowers with sufficient ground for concerns, have the right to take their allegations directly to the Chairman of the Company. The Chairman has the discretion to refer the allegations to the Management of the Company if he/she is of the opinion that the Management is without any conflict of interest and can more appropriately investigate the concerns raised.

5.5 if the Investigation Panels find the allegation unsubstantiated and all internal procedures have been exhausted, the Company recognizes the lawful rights of the whistleblowers to make disclosures to the relevant Government authorities, where justified.

6 OWNERSHIP OF POLICY

This WBP Policy is approved by the Board of Directors (BODs) of LLC Berhad on 01st January 2021. The BODs have overall responsibilities to ensure this policy remains consistent with the Board’s objectives and relevant standards of corporate governance.