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WhistleBlowing Policy

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PURPOSE
In line with the Code of Corporate Governance, TIME dotCom Berhad ("TdC") has adopted a Whistleblowing Policy, which outlines the Company's commitment to encourage employees to disclose any malpractice or misconduct (whistleblowing) of which they become aware and to provide protection for employees who report allegations of such malpractice or misconduct.

This Whistleblowing Policy provides clear procedure and framework by which directors, staff, contractors and consultants can confidently, and anonymously if they wish, voice concerns or complaints without fear of potential recrimination against them.


REPORTABLE MISCONDUCT
The following shall constitute "Reportable Misconduct" under this Whistleblowing Policy;
  • Failure to comply with any legal obligations
  • Conduct which violates any law or regulation including but not limited to Companies Act 1965, Computer Crimes Act 1997, MASB/FRS Standards, Anti Money Laundering & Anti-Terrorism Financing Act 2001, Bursa Malaysia Securities Berhad and Securities Commission Listing requirements
  • Breach of internal control, fraud or corruption
  • Violation of the Company's procedures, policies or other rules of conduct
  • Intentional misrepresentations directly or indirectly affecting financial statement
  • Damage to the environment
  • Danger to the health and safety of any individual
  • Non-disclosure or deliberate concealment that is subject to either internal or external audit process
  • Breach of confidentiality
  • Serious non-professional or non-ethical behaviour
  • The deliberate concealment of information which could lead to any of the matters listed above.


COMMUNICATION CHANNEL

The Whistleblower should initially communicate a Reportable Misconduct to the Head of Internal Audit.

TdC also has provided various avenues which employees, vendors or contractors are encouraged to use to report allegations of wrongdoing or unethical business behaviour such as follows:

Telephone: +603-5039 3607
E-Mail: whistleblower@time.com.my
Fax: +603-5032 6722
Mailing add: Head of Internal Audit,
TIME dotCom Berhad,
Level 4, No.14, Jalan Majistret U1/26,
Hicom Glenmarie Industrial Park,
40150, Shah Alam, Selangor, Malaysia.
   

The contact information will also be published on the company's intranet and website.

In the event the whistleblower suspects the Head of Internal Audit is involved, they should communicate to one or more of the following persons within the Company:

  • Chairman, Board Audit Committee
  • Chief Executive Officer


REQUIRED EVIDENCE
The Whistleblower should, at a minimum, be required to provide in the complaint or report, whether in writing or telephone, information regarding the type of activity or conduct constitutes the Reportable Misconduct, identify the person(s) suspected as being involved, when it occurred and who was affected. The information has to be first-hand knowledge of the facts disclosed in the Report.

In the event there is insufficient evidence to support their allegation, the Whistleblower should not be discouraged from making a Report.


WHISTLEBLOWER'S PROTECTION
TdC vendors, contractors or staff who lodge a complaint or report in good faith and in accordance with the Policy are protected against discrimination, harassment, being dismissed or penalized by TdC because of the complaint or report itself.

Making a complaint under the Whistleblowing Policy does not shield the person from the consequences of being involved in any improper conduct or unlawful activity alleged in a complaint under the Policy. However, in some limited circumstances, a full and frank admission may be a mitigating consideration in respect of disciplinary or other action.

Employee and industrial relations related issues and human resources related issues are excluded from the operation of this Policy because there are other established mechanisms to raise such complaints.

Whistleblowers making a Report in bad faith or based on unfounded allegations or containing trivial, malicious, slanderous or frivolous claims may be subject to disciplinary actions by the Company.



     
 
TdC Whistleblowing Policy Framework
 
     

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