Introduction

Our Whistleblower Protection Policy is aimed to provide an avenue for all employees and external parties (e.g. contract staff, customers, vendors/ suppliers, consultants) to disclose any improper conduct (as defined under the Whistleblower Protection Act 2010) committed or about to be committed to those in authority.

Objectives:

• To promote high standards of ethical conduct and open communication
• To ensure protection to the Whistleblower

Definition of Whistleblower

Any employee, shareholder or external party (e.g. contract staff, customers, vendors/ suppliers, consultants) who makes a disclosure to the authorised personnel of any wrongdoing activity within GTG, which he/ she reasonably believes may evidence an improper conduct.

The Whistleblower’s role is reporting party, not as an investigator. Although the Whistleblower is not expected to prove the truth of allegation, he/she shall sufficiently, demonstrate the grounds of concern.

Definition of Improper Conduct

Any conduct, deliberate act or failure to act, which if proved constitutes a serious matter (e.g. disciplinary or criminal offence), may adversely affect GTG’s performance and/or with the intention of obtaining an unauthorised personal benefit. Below are the examples of improper conduct, but not limited to:

• dishonest, fraudulent, corrupt or illegal practices;
• manipulation of accounts;
• unethical behaviour;
• abuse of power;
• violation of laws and constitution; or
• conflict of interest.

Disclosure Template

In writing please use a company form.

Disclosure Channels and Contact Details

1. Management Ombudspersons
2. Chief Compliance Officer, din@gtggroup.com.my
3. Chief Executive Officer (alternate), steve@gtggroup.com.my

1. By email:

• General Counsel: generalcounsel_wb@bnm.gov.my
• Director of LINK and BNM Offices: directorlink_wb@bnm.gov.my

2. Sealed letters with indicative labels such as “To be opened by [name of the Designated Person] only”, addressed to –

• [“Name of Appropriate Designated Person”]
  Bank Negara Malaysia
  Jalan Dato' Onn,
  50480 Kuala Lumpur, Malaysia

Suruhanjaya Pencegahan Rasuah Malaysia (“SPRM”) or Malaysian Anti-Corruption Commission (“MACC”)

1. Via online portal: http://portaladuan.sprm.gov.my/
2. By mail or hand-delivery with sealed enveloped marked “Strictly Private and Confidential”:

• MACC Headquarters
  No. 2 Lebuh Wawasan,
  Presint 7, 62250 Putrajaya.

Confidential Information

Reasonable efforts shall be made to ensure the confidential information is not disclosed unless absolutely necessary.

Protection for the Whistleblower

Whistleblower should be protected for reporting any actual or suspected improper conduct upon demonstrating sufficient basis for whistleblowing. GTG and/or employee shall not take any detrimental action against the Whistleblower in any manner, explicitly or implicitly.