WHISTLEBLOWING POLICY

INTRODUCTION

In line with good corporate governance practices, the Board and Management of Borneo Aqua Harvest Berhad and its group of companies (“the Company”) encourage its employees, directors and associates (“reporting individual”) to report suspected and/or known misconduct, wrongdoings, corruption and instances of fraud, waste, and/or abuse involving the resources of the Company. The policy provides an opportunity for those concerns to be investigated and for appropriate action to be taken to ensure that the matter is resolved effectively and within the Company whenever possible.

ISSUES AND CONCERNS THAT SHOULD BE REPORTED

The issues and concerns that shall be reported are as follows:
  • Unauthorized used of Company’s money, property and/or facilities;
  • Exposure of Company’s properties, facilities and/or staff to the risks of safety and security;
  • Negligence, abuse of position and/or failure to meet professional standards;
  • Commission of fraud and/or corruption;
  • Involvement of conflict of interests and/or business opportunities;
  • Non-compliance with Company’s policies, procedures and/or code of conduct;
  • Commission of unlawful acts;
  • Disclosure of Company’s information without proper authorization; and
  • Commission of acts which threaten, harass and/or victimize any members of the Board of Directors, Management or staff of the Company.

REPORTING PROCEDURE

The reporting procedures are as follows:

  • Any concern should be reported to the immediate superior. However, if it is not possible or appropriate to do so, the concern should then be reported to the Finance Manager/CEO.
  • Any concern that deemed not appropriate to be reported to the immediate superior should be raised to the attention of the CEO.
  • Upon receipt of the concern, the Finance Manager or CEO (depending on who is the recipient of the reporting) shall set up an investigating team (“Investigators”) to conduct investigation on the issue/concern raised.
  • The progress of the investigation shall be reported to the Finance Manager or CEO.
  • Upon completion of the investigation, the Investigators shall submit their full report together with recommendation to the Finance Manager or CEO.
  • Actions mandated shall be carried out accordingly.
  • If the whistleblower is not satisfied with the way the concern/matter is dealt with, he/she can escalate the report to the Audit Committee Chairman. The Audit Committee will deliberate the matter reported and decide on the appropriate action.

The information to be reported are as follows:

  • Type of fraud or irregularity,
  • Name of person/ persons involved,
  • Time, location and dates of fraud or malpractice occurred,
  • How the malpractice was committed,
  • Other witness to the fraud or malpractice, and lastly
  • Documentation or practice involved.

ANONYMOUS REPORTING

The whistleblower must identify himself when reporting suspected and/or known misconduct, wrongdoings, corruption, fraud, waste and/or abuse.

CONFIDENTIALITY AND RETALIATION

All whistleblower information will be kept confidential by the Company and will not tolerate any harassment or victimization and will take appropriate action to protect the person when he/she raises concern in good faith. Any party that retaliates against someone who has reported wrong doing in good faith may be subject to appropriate action, up to legal action, where applicable.

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