Whistle Blowing Policy

    WHISTLE BLOWING POLICY

    OBJECTIVE

    IDEALUBIB and its subsidiaries are committed to the values of transparency, impartiality, integrity and accountability in the conduct of its business dealings and affairs. The Company expects wrongdoings such as fraud, corruption, serious financial impropriety and mismanagement to be reported and facilitates this through internal mechanisms.

    This Policy is to provide an avenue for employees and stakeholders of IDEALUBIB to raise concerns and disclose any improper conduct in accordance with the procedures provided for under this policy and to provide protection for those who report such allegations.

    SCOPE

    This Policy is to facilitate employees and stakeholders to disclose any improper conduct (misconduct or criminal offence) through internal channel. Such misconduct or criminal offences include the following:

    • Fraud
    • Bribery
    • Abuse of Power
    • Conflict of Interest
    • Sexual Harassment
    • Theft or Embezzlement
    • Misuse of Company’s Property
    • Non Compliance with Procedure

     

    The above list is not exhaustive and includes any act or omissions, which if proven, will constitute an act of misconduct under the IDEALUBIB’s Code of Conduct or any criminal offence under relevant legislations in force. This Policy is for the employees and stakeholders to raise the matters in an independent and unbiased manner. Sufficient information is to be provided for the management to take appropriate steps.

    CONFIDENTIALITY

    All whistle blowing reports are treated as confidential and not to reveal the whistleblower’s identity. However, such consultation will not take place in the event the disclosure of identity is required by law. The whistleblower is to be given an assurance that his/her identity will only be known to a few top management on a need to know bases and the outcome of the investigation will be fed back to the whistleblower. This is to encourage and give confidence to the whistleblower 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 frivolous/malicious and not for personal gain, otherwise, disciplinary action may be taken against the whistleblower.

    PROTECTION TO WHISTLEBLOWER

    A whistleblower will be accorded with protection of confidentiality of identity, to the extent reasonably practicable. Whistleblower will also be protected against any adverse and detrimental actions for disclosing any improper conduct committed or about to be committed, provided that the disclosure is made in good faith. Such protection is accorded even if the investigation later reveals that the whistleblower is mistaken as to the facts and the rules and procedures involved.

    Any anonymous disclosure will not be entertained. However, the Company reserves its right to investigate into any anonymous disclosure.

    ADMINISTRATION AND REVIEW

    This Policy is administered by the Group’s Top Management and overseen by the Audit Committee. The Policy may be reviewed and amended, from time to time, as and when necessary to ensure its relevance and effectiveness in keeping with the Group’s changing business environment, administrative or operational need as well as changes in legislations.