Policy Statement
Melati Ehsan Holdings Berhad (“Melati” or “the Group”) is committed to conduct its business in accordance with the standard of corporate governance, business integrity and ethics.

In order to achieve this, the Board shall define a whistleblowing policy and create a whistleblowing reporting channel for employees and stakeholders (shareholders, customer and suppliers) to report any violation of laws and standards of corporate governance and ethics and to protect these individuals from reprisal and victimisation.

Application of the Policy
Under this policy, stakeholders may report concerns or allegations through the Group’s designated whistleblowing channel. Such concerns may cover improprieties of financial reporting, violation laws, anti-corruption and bribery policy, as well as but not limited to the following wrongdoings:

1. Abuse of power or authority;
2. Misrepresentation, fraudulent statements to shareholders, members of the investing public and authorities;
3. Manipulation of internal or external auditors in connection with examination and review of any financial statements or records of the Group;
4. Conflict of interest and insider trading;
5. Sexual harassment;
6. Money laundering;
7. Misappropriation of the Group’s properties, assets, resources or confidential information; and
8. Any combination of the above.

The above offences are not exhaustive. Stakeholders who wish to seek more clarifications on any reportable violations are encouraged to write to melati@whistleblower.com.my.

Principles of Whistleblowing
The principles underpinning the whistleblowing process are as follows:

1. Whistleblower is required to disclose his/her identity in order for the Group to accord the necessary protection to him/her;
2. By reporting to the Group of any suspected wrong doings, the whistleblower shall assure the Group that the information disclosed or reported by him/her is not confidential information which have been disclosed or reported to any enforcement agencies;
3. The identity of the whistleblowers will be kept in strict confidence. However, the whistleblower may be required to come forward as a witness in accordance with any applicable laws and regulations; and
4. All whistleblowers and any persons related or associated with the whistleblowers will be protected against any detrimental action, harassment or reprisal for whistleblowing. However, protection would not be extended to someone who raises a matter maliciously.

Reporting Channel
In order to protect the confidentiality of whistleblower and to ensure the integrity of the information received through the whistleblowing channel, the Board will maintain an independent whistleblowing reporting channel to enable all reported cases to be directly channelled to the Audit Committee.

Action
All reports received will be discussed and assessed by the Audit Committee based on, inter alia, the severity of the issue raised and the credibility of the information.

Upon assessment, the Audit Committee shall appoint suitable personnel either from within or outside the Group to review each complaint.

Upon completion of investigation, findings and recommendation for appropriate course of action shall be reported to the Audit Committee. The Audit Committee upon deliberation of the findings and recommendations shall report to the Board who shall then make a decision on:

1. Informing the whistleblowers of the status of the findings;
2. Initiating disciplinary action against wrong doer;
3. Making a police report where the improper conduct constitutes a criminal offence; and
4. Implementing measures to prevent similar incidents from happening in the future.

Board Review
The Board shall review and update this Policy periodically to ensure its relevance and effectiveness in keeping with the changes in legislation and the Group’s administrative and operational needs. Any revision and updates on this Policy will be approved by the Board and published on the Group’s website.