Whistleblowing Policy & Procedure

1. Objective

The Company is committed to ensure its business and operations are conducted in an ethical, moral and legal manner. In line with this commitment, the Company has put in place the Whistleblowing Policy and Procedure (WBP) to provide an avenue for all staff, interns, unit trust consultants, consultants, contractors, vendors, suppliers and/or unitholders to disclose any illegal, unethical, questionable practices or improper conduct committed or about to be committed within the Company. The disclosure shall be treated in strict confidence and without any risk of reprisal.

2. Scope of Reporting

Any irregularity and improper conduct, including but NOT limited to the following:

Fraud or Dishonesty
Theft or Embesslement
Bribery, Corruption
Abuse of Power
Breach of Applicable Law and Regulations, Including Any Illegal Activities
Breach of Company's Policies and Procedures (e.g. Code of Ethics, Staff Conduct and Discipline)
Insider Trading
Conflict of Interest
Improper Use or Falsification of Management and Financial Information
Misuse of Company's Property and Information
Bullying, Harassment, Sexual Harassment
Intimidation
Gross Mismanagement or Dereliction of Duties

3. Reporting Procedure

3.1	To report any irregularity/ misconduct committed or about to be committed (including any criminal offence), a whistleblower is required to provide the relevant details and send an e-mail to ALERT@publicmutual.com.my
3.2	The whistleblower is responsible to ensure that the disclosure is made in good faith, free from malicious intent and is not for personal gains.
3.3	This procedure strictly prohibits frivolous, vexatious, mala-fide, bogus disclosure for personal gain or with personal agenda. This is also not a channel for taking up any personal grievances.
3.4	If the subsequent investigation reveals that the disclosure was made with malicious intent, appropriate action can be taken against the whistleblower.

4. Reporting Channel

4.1	Disclosure via Protected Email Address at: ALERT@publicmutual.com.my

All of the above are secured and protected channels accessible only by authorised personnel.

5. Protection Accorded to Whistleblower

5.1	The Company will accord protection of confidentiality to the whistleblower to the extent reasonably consistent with the need to conduct an adequate investigation.
5.2	The Company will take all reasonable steps to protect the whistleblower against any discrimination, retaliation or harassment, corresponding to its internal policies and scope under its purview and jurisdiction.

6. Withdrawal of Disclosure

The whistleblower who wishes to withdraw his/her disclosure is required to write to ALERT@publicmutual.com.my, together with supporting reason(s) for the withdrawal. Notwithstanding such withdrawal, the Company reserves the right to proceed with investigation on the matters arising from the disclosure.

7. Other Reporting Channels

A whistleblower may also lodge a report with the police, the Securities Commission (SC), the Malaysian Anti-Corruption commission (MACC) or any other enforcement agency as defined under the Whistleblower Protection Act 2010 and forward a copy of the said report to the Company to enable the Company to conduct its own internal investigations.