Whistle blowing Policy

1. PURPOSE AND SCOPE

1. 1. The purpose of this Whistle Blowing Policy is to :
      1. Promote, develop and maintain a high standard of corporate governance, business integrity, transparency and accountability within the business operations of UPA Group of Companies.
      2. Provide a channel for all employees and related external partie to report on any possible violation, malpractice, misconduct and wrongdoings that may adversely affect the company.
      3. Provide an opportunity for the Directors or other authorised personnel to investigate on these reports and take appropriate actions thereon.
   2. The Whistle Blowing Policy is applicable to all companies under UPA Group of Companies. All permanent, contractual, and/or part time employees are subject to this policy while the related external parties include customers, suppliers, consultants, contractors and/or any party who has business dealing with UPA Group of Companies.
   3. The following are examples of violation, malpractice, misconduct and wrongdoing which fall under the scope of this policy :
      – corruption, bribery, acceptance of gifts and/or favours
      – Conflict of interest
      – Mishandling of company resources and assets
      – Forgery, cheating and criminal breach of trust
      – Non-compliance on legal or regulatory requirement
      – Disclosure of confidential information
      – Criminal offences
      – Failure to comply with safety, health and environment regulations
      – Sexual harassment
      – Failure to report any or a combination of the above

2. PRINCIPLES
The principles underlying this policy are :

1. 1. Protection
      Persons making genuine and appropriate complaints under this policy are assured of protection against unfair dismissal, victimisation, harassment and/or unwarranted disciplinary actions even if the complaints made turned out to be unsubstantiated.
   2. Confidentiality
      This policy provides an assurance that the identity of the whistle blower is to be kept confidential unless it is agreed otherwise.
   3. False reports
      This policy however does not extend confidentiality assurance to anyone who make a false report maliciously, with an ulterior motive or with personal gains. UPA Group of Companies reserve the right to take appropriate action against such individual.

3. REPORTING PROCEDURE

1. Any employee without malicious intent who believes that there are wrongdoings in the work place, he/she should report this to his/her immediate Supervisor. The Supervisor would then refer the report to the Group Administration & Personnel Department. The employee may also either report the wrongdoing direct to the Group Administration & Personnel Department or write in to [email protected]Related external parties may raise their report to Group Administration & Personnel Department or write in to [email protected]
2. However, if for whatever reasons that the employee or the related external parties feel uncomfortable with these channels, they may choose to report the complaints direct to Group Managing Director.Employee or related external party who choose to remain anonymous may direct their report in written form to the Group Administration & Personnel Department or direct to the Managing Director.

4. INVESTIGATIONS

1. All reports will be reviewed within reasonable timeframe. Due consideration will be given to each report and a decision will be made whether to proceed with a detailed investigation.The Director may assign the investigation to :
   – any senior management personnel,
   – risk management committee,
   – appropriate committee of the BoardThe investigation process includes collation of information and interviews with the witnesses. Employees who fail to cooperate, deliberately provide false information or concealing the truth in the investigation shall be subject to appropriate disciplinary action.Upon completion of investigation, appropriate course of action will be decided and all decisions made will be reported to the Audit Committee which would then report to the Board on quarterly basis.

5. REVIEW OF POLICY

1. This policy is approved and adopted by the Board of Directors on 5 June 2020. The policy is subject to review when necessary.