Whistleblowing Policy

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1. INTRODUCTION
Whistleblowing is an essential tool in the fight against corporate graft and malpractice, thereby enhancing the integrity, accountability and transparency within an organisation. This Whistleblowing Policy (“Policy”) serves to provide an effective whistleblowing mechanism for staff members of Engtex Group Berhad (“Engtex”) and its subsidiaries(“the Group”), and other relevant parties to voice genuine concerns in a responsible and effective manner.

2. OBJECTIVES
 

2.1

This Policy aims to establish a safe and effective mechanism for any concerned party to raise a bona fide concern to Engtex of any misconduct, wrongdoing, bribery & corruption, unlawful activities, fraud, abuse of power within the Group without fear of retaliation or victimisation.
  2.2 This Policy also outline the safeguards of individual who made the concern or reported the misconduct; (hereinafter called the “Whistleblower”) in order that appropriate remedial actions can be taken.

 

3. SCOPE
  3.1 This Policy is intended to address the Group and its subsidiary companies, its employees, its stakeholders, and members of the public who have genuine concerns.
  3.2 This policy is designed to:
    3.2.1 Support the Group’s values;
    3.2.2 Support the Group’s commitment to promote and maintain a high standard of transparency, corporate governance and business integrity;
    3.2.3 Provide a transparent and confidential process for dealing with concern by:
     
  • Facilitating the whistleblower to alert or report the impropriety without fear of reprisal, victimisation, harassment, subsequent discrimination or disadvantage;
  • Encouraging the whistleblower to raise genuine concern at the earliest opportunity, and in an appropriate way rather than overlooking the impropriety or reporting it outside the organization of the Group; and
  • Providing the avenues for the whistleblower to raise the concern and receive feedbacks on any action taken, including escalation if the concern is not satisfactorily addressed.


4. POLICIES

4.1 Whistleblower Protection and Safeguards  
  a) This Policy is designed to offer protection to those who made a concern, provided the concern is made in good faith and all concern raised will be treated fairly and properly. 
  b) Where an individual makes a concern in good faith and is reasonably believes it to be true, but the concern is not confirmed by subsequent investigation, no action will be taken against the individual. Such disclosure will retain anonymity unless the individual agrees otherwise. 
  c) The Group will not tolerate harassment or victimization of anyone who makes a concern. Retaliation is by itself misconduct and anyone engaging in retaliatory conduct will be subject to disciplinary action which may be pursued by the Group Human Resources & Administration Department, the Group Managing Director or the Audit Committee. 
   d) The Group, however, does not extend this assurance to an individual who maliciously raises a matter he/she knows is untrue. If an individual makes malicious concern, disciplinary action may be taken against the individual.
       
 4.2 Impropriety
  a) This policy is not designed to question financial or business decisions taken by the management of the Group, nor should it be used to reconsider any other matters which have already been addressed under other procedures or approved by management.
  b) There are existing procedures in place to enable an individual to lodge grievance relating to his/her own employment. As such, matters covered under employee’s grievances do not form part of this Policy.
  c) Concerns that may be raised include but not limited to the following: -
   
  • Fraud
  • Bribery & corruption
  • Blackmail
  • Misappropriation of funds or assets
  • Failure to comply with legal and regulatory obligations
  • Miscarriage of justice
  • Endangerment of an individual’s or public health and safety
  • Deliberately or accidentally steal, damage, or misuse data/information that are stored within the Group’s information system.
  • Sexual harassment or assaults
  • Insider trading
  • Concealment of any or combination of the above.


5. PROCEDURES

5.1 Making a Report 
  The whistleblower may raise concerns by filling up the prescribed Whistleblowing Form (Appendix 1) and attach relevant supporting documents and other audio and visual evidence and submit them via following channels:
  a) Email 
    Email to the Senior Independent Director, Dr. Teh Chee Ghee, through either of the following email address: 
      a) whistleblower@engtex.com.my (whistleblowing dedicated email address) 
      b) sbbeh@engtex.com.my (head of internal audit email address) 
  b) By Post 
    Mail to the Senior Independent Director, Dr. Teh Chee Ghee, Engtex Group Berhad (mark STRICTLY CONFIDENTIAL TO BE OPENED BY ADDRESSEE ONLY, via the following mailing address: 
      Attention to Mr. Beh Sui Boon (Head of Internal Audit, Sungai Buloh HQ) 
      Lot 36, Jalan BRP 9/2B, Putra Industrial Park, Bukit Rahman Putra, 47000 Sungai Buloh (Tel: 603-6140 1888) 
  a) Meet In Person (Walk-In, Texting, Video Conferencing, Calls) 
    Arrange for a meeting appointment with the Senior Independent Director, Dr. Teh Chee Ghee, by contacting: 
      Mr. Beh Sui Boon (Head of Internal Audit, Sungai Buloh HQ) 
      Lot 36, Jalan BRP 9/2B, Putra Industrial Park, Bukit Rahman Putra, 47000 Sungai Buloh (Tel: 603-6140 1888) 
    The whistleblower may choose to maintain anonymity but the Senior Independent Director reserves the right to decide whether to initiate investigation, depending on the merits and adequacy of initial evidence provided.
       
 5.2 Investigation and Follow-up
  a) Initial Assessment - The Senior Independent Director will assess the report received from whistleblower and determine whether the concern raised constitutes any wrongdoings as defined in this Policy. Additional information may be requested from the whistleblower. If the case is closed, the Senior Independent Director will inform the whistleblower on the decision.
  b) Investigation – The Senior Independent Director, is satisfied with the merits of the case base on initial assessment, may instruct the Group Internal Audit Department or an external independent party to carry out an investigation on the concerns raised by the whistleblower. During the period of investigation, the accused wrongdoer may be temporary reassigned to other department/function or asked to take leaves, pending the outcome of the investigation. Investigation report and accompanying recommendations shall be submitted to the Senior Independent Director and the Board of Directors to decide on the action.
  c) Communicating with Whistleblower - The Senior Independent Director shall inform the Whistleblower of the outcome of the investigation, however the details of the findings will not be disclosed for its confidentiality.
  c) Follow-up Actions – If the alleged wrongdoer is found to have committed misconduct, the Senior Independent Director will recommend appropriate actions to be taken against the wrongdoer, including but not limited to employment termination or reporting the case to the police or other relevant authorities.
 5.3 Confidential Whistleblowing
  a) The Group adopts the approach of confidential whistleblowing. The Group will respect and protect the confidentiality of the Whistleblower; and hereby gives the assurance that it will not reveal the identity of the whistleblower to any third party or other employees and public not involved in the investigation or prosecution of the matter unless he or she agrees otherwise. Where concern cannot be resolved without revealing the identity of the employee raising the concern (i.e., if the evidence is required in court), a dialogue will be carried out with the employee concerned as to whether and how the matter can be proceeded.
  b) The only exception to this assurance relates to an overriding legal obligation to breach confidentiality. The Group is obligated to reveal confidential information relating to a whistleblowing report if ordered to do so by a court of law.
  c) The Group assurance of confidentiality can only be completely effective if the Whistleblower likewise maintains confidentiality.


6. ADMINISTRATION

The Audit Committee is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed once every 2 years.