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INTRODUCTION

1.1. As part of the effort in promoting good corporate governance practices, Penang Development Corporation (“PDC”) and its subsidiaries (collectively known as “the Group”) have put in place a Policy on Whistleblowing (the Whistleblowing “Policy”) to facilitate the reporting of activities or practices that are in violation of the Group’s work rules.

1.2. This policy is designed to a) Support PDC Group’s Core Values; b) Ensure employees and external parties can raise concerns without fear of reprisals and safeguard such person’s confidentiality; c) Protect a whistleblower from reprisal as consequences of making a disclosure; d) Provide a transparent and confidential process for dealing with concerns

WHAT IS WHISTLEBLOWING?

2.1 Employees are expected to maintain and demonstrate the highest professional standards and ethical conduct in the performance of their duties. They are encouraged to report any violations or perceptions of violations of the Group’s work rules and/ or any unethical or unlawful business conduct, dealings or any suspicions of them, so that the necessary action can and will be taken by the Group to address the violations.

WHO IS A WHISTLEBLOWER?

3.1 A whistleblower can be an employee who, in the course of his/ her duties, has witnessed or believes that he/she has witnessed or believes that he/she has knowledge that another fellow employee has previously engaged in, is currently engaging in or is contemplating engaging in practices that will be in violation of the Group’s work rules, or unethical or unlawful business conduct or dealings, and decides to highlight these practices in order that the necessary corrective actions will be taken by the Group and to prevent the occurrence of such undesired practices.

3.2 Whistleblowing is not a means by which a disgruntled employee can abuse, wreak revenge on or sabotage another fellow employee without any just cause or to hold an employee to ransom. Any action of whistleblowing must be undertaken because the employees truly believe what they have witnessed or have otherwise become aware of a violation of the Group’s work rules or would otherwise constitute unethical or illegal business conduct.

3.3 Employees must be prepared to testify or provide evidence of such actions, where necessary. Incidents reported by way of anonymous letter will also be reviewed and investigated on the basis of their merits.

3.4 A whistleblower can be an external party who has a business relationship with the Group, including customers, suppliers, contractors and consultants.

3.5 A whistleblower need not have to be directly or indirectly affected by or have a personal interest in the outcome of the actions giving rise to the whistleblowing. As long as a whistleblower has a genuine concern and reasonable grounds to believe that the actions of an employee is in breach or will be in breach of the Group’s work rules or principles of ethical conduct and fair dealing, he/she can be a whistleblower. However, a whistleblower must act in good faith at all times.

WHAT SHOULD BE REPORTED?

4.1 Some examples of concerns covered by this Whistleblowing Policy include, but are not limited to:

• Concerns about the Group’s accounting, internal controls and auditing matters;

• Fraud or suspected fraud, thefts and dishonest acts;

• Profiteering as a result of insider knowledge;

• Accepting or giving bribes;

• Mismanagement within the Group (including serious potential breach to the interest of society and environment);

• Act or omission jeopardizing the health and safety of the Group’s employees or the public;

• Making of statements or remarks which will be defamatory or cause disruption to racial harmony, sexual harassment or adopting discriminatory practices;

• Misappropriation of funds; and • Conduct which is an offence or breach of law.

WHEN TO REPORT?

5.1 When the whistleblower reasonably believes that the incident is happening now, has already happened, or is likely to happen.

HOW TO REPORT?

6.1 Whistleblowers can raise their concerns with either one of the following:

a) Head of Internal Audit via an email sent to This email address is being protected from spambots. You need JavaScript enabled to view it. or via a written letter to PDC’s office under Private & Confidential cover

b) Chairman of the Audit Review Committee via a written letter to PDC’s office under Private & Confidential cover

6.2 The following key information should be provided :

• Alleged event that is of concern and the details involved • Name of person(s) and/ or department(s) involved (including external parties)

• Approximate date/location of the incident • Any documents or evidence available to support the matter

6.3 Whistleblowers are encouraged to provide their names so as to facilitate the investigations and the subsequent feedback. Confidentiality will be ensured. Anonymity is not encouraged as it can make investigations difficult or impossible.

PROTECTION FOR WHISTLEBLOWER

7.1 The Group assures that the whistleblower’s identity will be kept confidential unless required by law, by the court or other regulatory authorities to disclose his or her identity.

7.2 The Group will not tolerate any form of retaliation by anyone against the whistleblower and disciplinary action will be taken against those who victimize the whistleblower.

MALICIOUS OR FRIVOLOUS REPORTING

8.1 Only genuine concerns should be reported. Disclosure must be made in good faith with a reasonable belief that the information is true.

8.2 When allegations are done with malicious intent or ulterior motive for personal gain, disciplinary actions will be taken against the whistleblower concerned.

HOW THE GROUP WILL RESPOND

9.1 The Group assures the whistleblower that any concern raised or information provided will be investigated but consideration will be given to these factors :

• Severity of the issue raised

• Credibility of the concern or information

• Likelihood of confirming the concern or the availability of information from attributable sources

9.2 Depending on the nature of the concern raised or information provided, the investigation may be conducted involving one or more of these persons or entities:

• The Audit Review Committee

• The Internal Auditors

• The External Auditors, Forensic Professionals or other consultants as deemed appropriate

• The Royal Malaysian Police, Malaysian Anti-Corruption Commission or other relevant enforcement agencies 9.3 The frequency of contact between the whistleblower and the person(s) investigating the concern raised and information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistleblower during the course of the investigation.