OBJECTIVES

The Board of Directors (“the Board”) of Extol Corporation Sdn Bhd (“the Company”) is committed to achieving and maintaining the highest standard of work ethics in the conduct of business in line with the code of conduct & ethics and good corporate governance practices, the Company and its subsidiaries (“the Group”) encourage its employees to report suspected and/or known misconduct, wrongdoings, corruption and instances of fraud, waste, and/or abuse involving the resources of the Group.

This policy is to provide an avenue for all employees of the Group and members of the public to disclose any improper conduct in accordance with the procedures as provided for under this policy and to provide protection for employees and members of the public who report such allegations.

The policy is designed to support to the following:

1. Be committed to the Company’s business ethics of Honesty, Integrity and Transparency;
2. To provide a transparent and confidential process for all parties to give information on non-compliances to the Code of Ethics and Conduct, or any misconduct regardless of his or her position, to an independent party to investigate the allegations and take the appropriate actions; and
3. To uphold the moral duty being a Company by protecting the interest of all its stakeholders.

DEFINITION OF REPORTED MISCONDUCT

An improper conduct is any act or omission, which if proven, will constitute an act of misconduct pursuant to the Group’s Code of Ethics and Conduct and/or a criminal offence under the relevant law in force and may be divided into the following categories:

1. General Misconduct
   1. use of vulgar or abusive language/behaviour against fellow colleagues or a superior or any person having business with the Company;
   2. intentional insubordination or disobedience whether alone or on combination with others to any lawful and reasonable instructions of a superior or those acting under the instruction of a superior, which the employee is required to follow;
   3. intentional slow-down of work and/or influence others to do so or conduct that is disrupting other colleagues;
   4. threatening or use of violence and or oppression against another employee or persons having dealings with the Company;
   5. use of Company’s property or facilities for purposes of committing or attempting or preparing to commit a misconduct; and
   6. sexual harassment by or any person(s) employed is strictly prohibited. The provisions contained in the “Code of Practice on the Prevention and Eradication of Sexual Harassment in the Workplace” issued by the Malaysia Ministry of Human Resource are to be observed.
2. Unlawful/Illegal Conduct/Intention
   1. Fraudulent case;
   2. Dishonesty, corruption, bribery, blackmail;
   3. Failure to comply with any legal/regulatory obligation;
   4. Breach of law, rules and regulation; and
   5. Cheating, theft and corruption.
3. Unprocedural Conduct/Act
   Actions/conduct which violates clearly communicated procedures that governing operations of the Company and such procedures are important for good governance and breaching may expose the Company to risk of loss or actual loss.
4. Conflict of Interest
   1. All employees are not allowed by knowingly place him/herself in a position conflict with the interest/ statutory duties in the Company and shall at all time, avoid being caught in situation of conflict of interest;
   2. Employees has to ensure that their personal financial circumstances and transactions do not jeopardise their independent judgement or adversely affect their job performance; and
   3. Employees must not have any direct or indirect involvement in other employment (remunerated or otherwise) except otherwise agreed by the management.
5. Unethical Conduct
   1. Caused damage to the environment;
   2. Religious or racial or sexual discrimination;
   3. Serious non-professional or non-ethical behavior; and
   4. Caused danger to the health and safety of any individual.

The above list is not exhaustive and includes any act or omissions, which if proven, will constitute an act of misconduct under the Company’s Code of Conduct and Ethics or any criminal offence under relevant legislations in force.

CONFIDENTIALITY AND ANONYMITY

All whistle-blowing reports are treated as confidential and or anonymous and not to reveal the blower’s identity, if so wish. However, such consultation will not take place in the event the disclosure of identity is required by law. The whistle-blower is to be given an assurance that his/her identity will be only known be a few top management on a need to know basis and the outcome of the investigation will be fed back to the whistle-blower. This is to encourage and give confidence to the whistle-blower that the complaint will be investigated.

All whistle-blowing reports have to be made in good faith with reasonable belief that the information and allegation is true and not frivolously/ maliciously and not for personal gain; otherwise, disciplinary action may be taken against an employee whistle-blower.

PROTECTION TO WHISTLE-BLOWER

This policy provides assurance that the whistle-blower, if an employee of the Company, shall be protected against reprisals or retaliation, and immunity from disciplinary action from the whistle-blower’s immediate supervisor or department/division head or any other person exercising power or authority over the whistle-blower in his/her employment, provided that:

1. only genuine concerns are reported, and the report is made in good faith with a reasonable belief that the information and any allegation in it are substantially true, and the whistle-blower does not provide false or misleading information knowingly, negligently or recklessly in the report;
2. the disclosure is not made with malicious intent or ill will;
3. the disclosure is not frivolous or vexatious; and
4. the report is not made for personal gain or agenda.

We trust that every whistle-blower must conduct themselves with high integrity and responsibility. To establish a sound relationship of trust, individuals who make disclosures are encouraged to identify themselves and their contact (phone number/email). This is especially so when more detail information is required. Whenever necessary, the whistle-blower may be required to stand as a witness for the Company for the appropriate disciplinary action to be effective.

All information received will be treated with strictest confidentiality.