GUH HOLDINGS BERHAD GROUP
OF COMPANIESGROUP POLICY & PROCEDURES
WHISTLEBLOWINGGUH HOLDINGS BERHAD GROUP
GROUP POLICY & PROCEDURES
WHISTLEBLOWINGCONTENTSSECTION

TITLE

PAGE

1.0

INTRODUCTION

12.0

SCOPE

13.0

DEFINITION

14.0

REFERENCE

25.0

EFFECTIVE DATE OF IMPLEMENTATION

26.0

GROUP POLICY AND GUIDELINES

7.0

6.1

Roles & Responsibilities

26.2

Example of Misconduct

36.3

Record Keeping

4

PROCEDURES
7.1

Reporting & Disclosure

47.2

Treatment & Investigation of Disclosure

57.3

Disciplinary Action

68.0

PROCEDURES NOT COVERED UNDER POLICY

79.0

POLICY GOVERNANCE

710.0

APPENDICES
Appendix I- Disclosure Form8GUH HOLDINGS BERHAD GROUP
GROUP POLICY & PROCEDURES
WHISTLEBLOWING
1.0

INTRODUCTION
GUH Group is committed to a culture of high corporate compliance and high ethicalbehavior. As the highest standard of integrity is expected from all of its employees, theGroup takes a serious view on any misconduct by its employees, management and directors,
in particular with respect to their obligations to the Group’s interests.
Whistleblowing channels have been established to help stakeholders raise concerns, without
fear of retaliation, on any wrongdoing that they may observe in the Company.
The objectives of this policy and guidelines are to:(i)Enable internal and external parties to raise concerns in relation to real or suspected
corruption incidents or inadequacies of the Company’s anti-corruption programme;(ii) encourage employees and third parties (hereinafter collectively referred to as“stakeholders”) to disclose any malpractice or misconduct (whistleblowing);(iii) ensure that all disclosures are investigated according to procedures prescribed andrectifying actions are taken;(iv) provide a guideline for stakeholders on the approach to whistleblowing;(v)

provide protection to employees who report alleged misconduct;(vi) build and strengthen a culture of transparency and trust in the Company.

2.0

SCOPE
This policy and guidelines shall be applicable to employees of GUH Holdings Berhad, its
wholly owned subsidiaries and sub-subsidiaries in Malaysia and elsewhere.

3.0

DEFINITION
3.1 Whistleblowing:

the disclosure by a stakeholder to those in authority, ofconcerns in relation to real or suspected corruption incidents
or inadequacies of the Company’s anti-corruption
programme.

3.2 Whistleblower:

any stakeholder who makes a disclosure of concerns inrelation to real or suspected corruption incidents orinadequacies of the Company’s anti-corruption programme.

3.3 Investigation Officer :the party whom disclosure is made and has the responsibility
to carry out/delegate the investigation on the disclosure
received.

3.4 Misconduct

an act of commission
or omission by an employee which:contravenes or conflicts with the established rules andregulations of the Company, if proven would warrant:

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WHISTLEBLOWING
disciplinary action.

4.0

3.5 Disclosure:

the improper misconduct of employees in the Company makeknown to those in authority by stakeholder (whistleblower).

3.6 Good faith:honesty and sincerity of intention.

REFERENCE
4.1 Whistleblower Protection Act 2010;
4.2 Group’s Policy & Procedures on Disciplinary Procedures; and4.3 GUH Holdings Berhad’s Anti-Bribery and Corruption Policy and Procedures.

5.0

EFFECTIVE DATE OF IMPLEMENTATIONThis policy and guidelines shall be implemented with immediate effect and shall remain inforce until such time when a review, in whole or in part, is deemed necessary.

6.0

GROUP POLICY AND GUIDELINES
6.1 Roles & Responsibilities
6.1.1 The Company(i)the Company will take all reasonable steps to protect the identity of thewhistleblower, if practicable;(ii)

where the identity of the whistleblower is to be disclosed, thewhistleblower should be informed of this in advance;(iii)

the Company will not discharge, discipline, demote, suspend, threaten orin any manner discriminate against any employee who makes a disclosurein good faith, or provide assistance to facilitate the investigation;(iv)

retaliation against whistleblowers under this policy is strictly prohibited;
and

(v)

any employee of the Company determined to have engaged in retaliation
behavior may be subjected to disciplinary action.

6.1.2 Whistleblower(i)to disclose in good faith with a reasonable belief that the information andallegations are substantially true, must have reasonable evidence, notbased on hearsay and that the report is not made for personal benefit;(ii)

to be protected even if the allegations prove to be incorrect or
unsubstantiated, provided that Clause 6.1.2 (i) is met at the first place;

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GUH HOLDINGS BERHAD GROUP
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WHISTLEBLOWING

6.1.3

(iii)

disclosure shall not be made to the other parties unless no further action istaken within 3 working days after the whistleblowing;(iv)

confidentiality of identity is protected but is not fully assured as thenature of the disclosure might require the identity to be revealed;(v)

if it is found that the whistleblower knew or believed that the disclosure
made was false, the disclosure will be treated as “null and void”. If thewhistleblower is an employee of the Company, disciplinary action will betaken against him/her; and(vi)The employee (whistleblower) who fears or has suffered detrimental
action may request to the Company by apply in writing for relocation ofplace of employment.

Investigation Officer(i)to ensure the disclosure and identity of whistleblower are kept
confidential at reasonable efforts; and(ii) to carry out investigation on the allegations by being objective andprudent throughout the investigation.
6.2 Example of Misconduct
6.2.1 The following are some examples of misconduct (non-exhaustive):(i)dishonest;(ii)

fraudulent;(iii)

criminal damage against property;(iv)

discriminatory;(v)

sexual harassment;(vi)suspected, attempted or actual corruption or bribery;(vii)

act or omission which poses threat on lives, health and safety of theemployees, public or environment; and(viii)

act or omission that lead to contravention of country civil law.

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GUH HOLDINGS BERHAD GROUP
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WHISTLEBLOWING
6.3 Record Keeping

7.0

6.3.1

All documentation and records related to the disclosure, investigation and thesubsequent disciplinary action (if wrongdoings are established) shall beproperly maintained by the HR Department.

6.3.2

The investigation report shall be maintained by the Investigation Officer andHR Department.

PROCEDURES
7.1 Reporting & Disclosure
7.1.1 Any stakeholder who has a concern or reasonable belief that a misconduct has
occurred or that there are inadequacies in the Company’s anti-corruption
programme and is apprehensive about raising his/her concern due to the fear ofpossible adverse repercussion to him/her is encouraged to use the reporting
procedures outlined as below:(i)a disclosure can be made in by writing using the Disclosure Form (Referto Appendix I) via post to:
Human Resource Department
GUH Holdings BerhadPart of Plot 1240 & 1241,
Bayan Lepas Free Industrial Zone,
Phase 3, Bayan Lepas,11900 Penang,Malaysia.
oremail to:whistleblowing@guh.com.my;(ii)

the Disclosure Form has to be filled up completely by enabling or
facilitating the Company in carrying out the necessary investigation jobs.
Incomplete Disclosure Form will be treated as “null and void”; and(iii)

the whistleblower can choose not to disclose his/her particulars in thedisclosure but is encouraged to leave a source of contact for future
investigation purposes.

7.1.2 It is encouraged that the whistleblower to make the disclosure within 14 calendar
days or reasonable timeframe of coming upon such information or document.
Delaying the disclosure may be detrimental to the whistleblower and affects theinvestigation.

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WHISTLEBLOWING
7.2 Treatment & Investigation of Disclosure
7.2.1

The recipients of the disclosure, the Legal and HR Departments, shall perform
preliminary assessment on the disclosure received.

7.2.2

The disclosure will be referred directly to the Independent Non-Executive
Director (“INED”) / Audit Committee (“AC”) Chairman under the following
circumstances:-(i)the disclosure involves CEO/ Group Managing Director; and(ii)the risk or adverse impact to the Company is high.

7.2.3

Apart from situation mentioned under Clause 7.2.2, the disclosure will bereferred to CEO/ Group Managing Director.

7.2.4

Rejection of disclosure could be due to the following reasons:(i)the disclosure is not made in good faith or made with the intention gaining
personal benefit;(ii)

the disclosure is made anonymously and there is insufficient information
for investigation to be carried out; and(iii) the subject matter of the disclosure has been satisfactorily dealt with orresolved through another policy or procedures (e.g. personal grievances).
7.2.5

Otherwise, upon acceptance of the disclosure, the recipients should acknowledge
and notify whistleblower within 3 working days from the received date that thedisclosure will undergo investigation process or has been rejected (provided thatthe reason(s) for such rejection is given).

7.2.6

The recipients may, upon obtaining the management’s feedback pursuant toreferences under clauses 7.2.2 or 7.2.3, act as the investigation officers or appointa suitable party (e.g. HOD, Head of Internal Audit, External Consultant, LegalAdvisor, etc.) to carry out the duties and responsibilities set out in Clause 6.1.3
above.

7.2.7

The investigation plan and appropriate method to carry out the investigation isdetermined by the Investigation Officer.

7.2.8

The Investigation Officer shall own the right to take statements from whoever
deemed relevant and significant to the investigation, including the whistleblower.

7.2.9

Upon completion of the investigation, the Investigation Officer should submit theinvestigation report to the CEO/ Group Managing Director or INED/ ACChairman if situation mentioned under clause 7.2.2 for further actions.

7.2.10 If it is proven that the allegation is true, the CEO/ Group Managing Director orINED/ AC Chairman who has the authority to make final decisions may perform
but not limited to the following:

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GUH HOLDINGS BERHAD GROUP
GROUP POLICY & PROCEDURES
WHISTLEBLOWING(i)take appropriate actions in accordance with the Group’s Policy andProcedures on Disciplinary Procedures or direct the strengthening of theAnti-Bribery and Corruption Policy and Procedures, if appropriate andapplicable;(ii) suspending the alleged wrongdoer and any other implicated person fromwork to facilitate any fact-finding or to avoid any employee’s exposure to atreat or harm;(iii) obtaining any further assistance (e.g. external consultants or legal advice);and(iv) referral to the police or any other appropriate enforcement authority.
7.2.11 The investigation results should be presented in the form of report with thefollowing highlights:(i)

details of the misconduct and wrongdoers (name, date, incident, etc.);(ii)

evidence of misconduct, if practicable;(iii) any action that should be taken to remedy any harm or loss arising fromthe misconduct, including the disciplinary action against the wrongdoers;(iv)

recommendations of precautionary steps to prevent the conduct fromoccurring in the future, if any; and(v)referral of matter to appropriate authorities, if deemed necessary.

7.2.12 If the wrongdoing is being established, the HR Department should inform theHead of Department of the wrongdoer(s) and the Whistleblower about theresults. A copy of the investigation report will be maintained by the HRdepartment for filing purpose.
7.2.13 If no wrongdoing is being established, HR Department should inform theWhistleblower about the results. A copy of the investigation report will bemaintained by the HR department for filing purpose.

7.3 Disciplinary Action
7.3.1 The HR department shall be in charge of carrying out the disciplinary action
against the wrongdoer(s) once CEO/ Group Managing Director or INED/ AC
Chairman decided that the wrongdoer(s) is subjected to disciplinary action(s)stipulated in the Group’s Policy & Procedure - Disciplinary Procedures.
7.3.2 If it is found that the employee (whistleblower) knew (or should reasonably
have known) or believed that the disclosure made was false, likely to be false,or frivolous, disciplinary action will be taken against him/her in accordance tothe Group’s Policy & Procedure - Disciplinary Procedures by HR department.

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GROUP POLICY & PROCEDURES
WHISTLEBLOWING
8.0

PROCEDURES NOT COVERED UNDER POLICY
In the event that:(i)(ii)(iii)

a procedure relating to whistleblowing which is not included in this manual;an employee has a query relating to the procedure under this policy; ora company procedure not covered under this policy.

the matter shall be referred in the first instance to the Division Head, who may thereafterrefer to the CEO/ Group Managing Director for guidance, if required.

9.0

POLICY GOVERNANCE
The content of this policy may be reviewed from time to time by the Company in its absolute
discretion to suit the constantly evolving organization and regulatory requirement changes.
Any amendments to the policy shall be approved by the CEO/ Group Managing Director or
INED/ AC Chairman.

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GUH HOLDINGS BERHAD GROUPAPPENDIX ICOMPANY LETTERHEAD

Case Reference No.:
PostEmailDISCLOSURE FORM
Company:

Name of involved person(s)Designation/Department ofinvolved person(s)Disclosure details (Please attach
separately if necessary and sign off
at the end of each attachment)
Date of incident (if applicable)
Location of incident (if applicable)
Estimated value of incident, inRinggit Malaysia (if applicable)
Supporting evidence (Please attach
separately, if any)
DECLARATIONI hereby declare that the details furnished above are true and correct to the best of my knowledge and belief
and I undertake to inform you of any changes therein, immediately.

…………..…………..……
NameContact No
EmailDate Reported::::

Acknowledged by:….......................................................
Name:
Designation:
Date:
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