Whistle Blowing Policy and Procedures

Policy Statement

a)	This Code provides 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 the SEB’s Principles of business, all employees and stakeholders (i.e. shareholders / suppliers / customers) are encourage to report genuine concerns about unethical behavior, malpractices, illegal acts or failure to comply with regulatory requirement without fear of reprisal should they act in good faith when reporting such concerns.
c)	SEB’s views any harassments or relations 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)	The policy and procedure is applicable to all companies within: SEB’s Group.

Whistle Blowing

a)	Whistle Blowing is a specific means by which a worker or stakeholder can report or disclose thought establish channels, concerns about unethical behavior, 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. This 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 personnel gain. Malicious and false allegations will be viewed seriously and treated as gross misconduct and if proven may lead to dismissal.

Procedures

Any concern should be raised with 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:

Name	:	Mr . See Boon Chun
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 Operating Officer and Executive Director
Email	:	see.bc@seb.net.my

In the case 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:

Name	:	Chan Foong Ping
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

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)	Reports received anonymously will be treated confidential.
c)	The person making an investigation. Irrespective of this, anonymity will be maintained as long as it’s permitted by law or the person making the report indicates that he no longer wishes to remain anonymous.
d)	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.
e)	Where possible, steps will also be implemented to prevent similar situation arising.

Further action

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

Name	:	Chan Foong Ping
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

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

Whistle Blowing Policy and Procedures

Whistle Blowing Policy and Procedures

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