1. Policy Statement

• Tomei Consolidated Berhad and its subsidiary companies (“Tomei” or “the Group”’) are committed to achieve and maintain high standards with regards to behavior at work as set out in its Code of Conduct.

• In order to achieve the standards set out in the Group’s Code of Conduct, all employees and other stakeholders including shareholders, suppliers and customers are encouraged to report genuine concerns on acts committed by employees and directors arising from unethical behavior, malpractices, illegal acts or failure to comply with regulatory requirements without fear of reprisal provided they act in good faith when reporting such concerns.

• This policy protects a whistleblower who lodges a report/complaint against an employee and/or director from any adverse employment action. Tomei views any harassments or retaliations in any form or manner against genuine whistleblower seriously and will treat such action as gross misconduct, which if proven, may lead to dismissal.
  
  

2. Whistleblowing

• Whistleblowing is a specific means to guide employee or any stakeholder of the Group to report or disclose through established channels on matters , concerning
  
  i)      criminal offences including bribery, fraud, corruption or abuse of power;
  ii)     misappropriation of funds, assets, theft or embezzlement or gross mismanagement;
  iii)    financial irregularity;
  iv)    breach of Company’s Code of Conduct;
  v)     failure to comply with provisions of laws or regulations; and
  vi)    serious conflict of interest without disclosure.
  vii)   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.

• 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 personal gain.

• Employees are advised to exercise due care to ensure the accuracy of the information given. If an employee makes mala fide report and if proven, disciplinary action may be taken against such employee. If a vendor lodges mala fide report, the Group may consider lodging a police report and/or take other necessary actions deemed appropriate.
  
  

3. Procedures

•  Any complaint in relation to whistleblowing should be brought up directly to the Chairman of the Audit and Risk Management Committee at [email protected].
  
  

4. Action

• All reports and identity of the whistleblower will be treated in a confidential and sensitive manner. A report will only be disclosed to those who are authorised to carry out investigation into matters relating to the report.

• The Group encourages the whistleblower to state his/her name to their respective report, whenever possible. Any person making anonymous report will be advised that maintaining anonymity may hinder 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.

• Any decision taken by the Audit and Risk Management Committee will be referred to the Board of Directors for endorsement before implementation.

• Where possible, remedial actions will also be implemented to prevent similar situation from arising in future.