Whistle Blowing Policy and Procedures

Policy Statement

a)	This Whistle Blowing Policy and Procedures (the “Procedures”) provide ethical and legal guidance to all Affected Personnel in the conduct of their business and that of the SEB Group.
b)	In order to achieve the standards set in SEB’s Principles of business, all employees and stakeholders (i.e. shareholders / suppliers / customers) are encouraged to report genuine concerns about unethical behaviour, malpractices, illegal acts or failure to comply with regulatory requirements; without fear of reprisal should they act in good faith when reporting such concerns.
c)	SEB views any harassment or retaliation in any form or manner against genuine whistle blower seriously and will treat such action as gross misconduct, which if proven, may lead to dismissal.
d)	This policy and procedure is applicable to all companies within the SEB Group.

Whistle Blowing

a)	Whistle Blowing is a specific means by which a worker or stakeholder can report or disclose through established channels, concerns about unethical behaviour, malpractices, illegal acts or failure to comply with regulatory requirements that is taking place / has taken place / may take place in the future.
b)	Only genuine concerns should be reported under Whistle Blowing procedures. The report should be made in good faith with a reasonable belief that the information and any allegation in it are substantially true, and the report is not made for personal gain. Malicious and false allegations will be viewed seriously and treated as gross misconduct and if proven true, may lead to dismissal

Procedures

Any concern should be raised with the immediate superior. If for any reason, it is believed that this is not possible or appropriate, then the concern should be reported to The Chief Executive Officer. Channels of reporting to CEO are:


Telephone	:	06-6775898
Mail	:	Lot 1A-1C, Lorong Bunga Tanjung 1/3 Senawang industrial Park, 70400 Seremban Negeri Sembilan Darul Khusus [Mark Strictly Confidential]
Attention	:	Chief Executive Officer
Email	:	ceo@seb.net.my

In cases where reporting to management is a concern, then the report should be made to the Chairman of Audit Committee. Channels of reporting to the Chairman of Audit Committee are:

Telephone	:	06-677 5898
Mail	:	Lot 1A-1C, Lorong Bunga Tanjung 1/3 Senawang industrial Park, 70400 Seremban Negeri Sembilan Darul Khusus [Mark Strictly Confidential]
Attention	:	Chairman – Audit Committee
Dedicated Email	:	ac@seb.net.my

Action

a)	All reports will be investigated promptly by the person receiving the report. If required, he can obtain assistance from other resources within the Group (e.g. Group Finance Department and Group Human resources Department, etc.) The progress of investigation will be reported to the Audit Committee no later than at the next scheduled meeting.
b)	Should the whistle blower identify him/herself, the identity of the whistle blower will not be disclosed to preserve his/her anonymity for as long as it is permitted by law or when the whistle blower decides otherwise.
c)	All whistle blower reports will be treated as confidential irrespective of whether the whistle blower identifies him/herself when reporting.
d)	All whistle blower reports will be taken seriously and investigated irrespective of whether the whistle blower identifies him/herself.
e)	Upon completion of investigation, appropriate course of action will be recommended to the Audit Committee for their deliberation. Decision taken by the Audit Committee will be implemented immediately.
f)	Where possible, steps will also be implemented to prevent similar situation as that reported from recurring.

Further action

If for any reason, the person making the report is not satisfied with the way his/her report had been dealt with, he/she can escalate his/her report to the Chairman of Audit Committee personally. Channels of reporting to the Chairman of Audit Committee are:

Telephone	:	06-677 5898
Mail	:	Lot 1A-1C, Lorong Bunga Tanjung 1/3 Senawang industrial Park, 70400 Seremban Negeri Sembilan Darul Khusus [Mark Strictly Confidential]
Attention	:	Chairman – Audit Committee
Dedicated Email	:	ac@seb.net.my

Chairman of Audit Committee will deliberate the report with his/her Committee members and decide on the appropriate course of action.

Approved by the Board on 23 November 2018

Updated as at 11 October 2019

Whistle Blowing Policy and Procedures

Whistle Blowing Policy and Procedures

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