Whistleblowing Policy

Objective

The Ethics / Corporate Responsibility Unit (ECRU) is established to implement whistleblowing (ie. public interest disclosure) procedures in GD Express Carrier Bhd & its group of companies (GDEX).

Scope Of Work

  • To issue whistleblowing policy & procedures in GDEX.
  • To receive reports from whistleblowers.
  • To investigate all reports from whistleblowers and to present these reports to the Audit Committee (AC) with its initial findings for AC further action.

Line of Responsibility

Report directly to Chairman of AC.

General Principles

ECRU will ensure the following general principles will apply in GDEX:

  • To encourage culture of openness, accountability and integrity.
  • To establish formal mechanisms for reporting.
  • To establish clear communications about the process of reporting.
  • To ensure confidentiality and anonymity.
  • To prevent punishment or unfair treatment of employee who reports in good faith.
  • To ensure no mis-use of whistleblowing procedure.
  • To safeguard position of the person who is subject of report.
  • To notify reporter of outcome of findings.

Evaluation

GDEX whistleblowing procedure will be part of the annual cycle of monitoring compliance related to Corporate Governance. Annually ECRU will present an evaluation report of its activities and findings to AC of the Board of Directors.

ANNEX I

GDEX WHISTLEBLOWING POLICY & PROCEDURES

Objective

The objective of GDEX Whistleblowing Policy & Procedures (WBPP) is to ensure that each and every employee of GDEX, through understanding the WBPP, will come forward to express his or her concerns about a (suspected) malpractice, without fear of punishment or unfair treatment.

This WBPP will guide GDEX employee on how to raise such concerns.

Definition

Whistleblowing is a term used for what is legally known as Public Disclosure Policy, which is when an employee discloses information about malpractice or wrongdoing they discover occurring in GDEX.

What To Report

The malpractices or wrongdoings that an employee should report under WBPP are:

  • non compliance to laws and regulations
  • financial malpractice
  • discrimination
  • danger to public or employee health and safety
  • concealment of any malpractice
  • criminal activity

The procedures under WBPP should NOT be used for:

  • poor performance
  • lack of professionalism
  • personal disputes
  • personal grievances

Sometimes it is not clear whether a particular action falls under the malpractices described above. In such cases, GDEX would prefer that the employee report his or her concerns in good faith rather than to keep to himself or herself.

Importance Of WBPP To GDEX

  • enable management to be informed at an early stage about possible contraventions
  • support a culture of openness, accountability and integrity
  • ensure good corporate governance and curb unethical and illegal practices at all levels
  • minimize harm and damage to GDEX and its stakeholders

Role Of Every GDEX Employee

  • every GDEX employee to be aware and understand the WBPP
  • every GDEX employee to understand the importance of whistleblowing
  • every GDEX employee to be encouraged to whistleblow on malpractices as listed above

Reporting Rules & Procedures

  • GDEX employee should report any malpractice or wrongdoing to Ms Lisa Chan, the Head of the Ethics / Corporate Responsibility Unit (ECRU) who reports directly to an Independent Non-Executive Chairman.
  • The report can be made in the following manner:
    1. verbally to Lisa Chan
    2. by sms to handphone no: 016 339 0719
    3. in writing addressed to Lisa Chan
  • he reporting employee can choose to remain anonymous.
  • The ECRU will ensure all information received will be kept in strictest confidence. The name of the reporting employee will be kept confidential at all times.
  • The reporting employee will be given protection and will not be punished or treated unfairly if the reporting is made in good faith.
  • If upon investigation by ECRU the reported concerns cannot be confirmed or may not have substance, no action will be taken against the reporting employee raising the concerns in good faith.
  • The reporting employee will not be required to testify against the reported person in any hearings if this is requested by the reporting employee.
  • An employee who mis-used the WBPP by purposely making a false report may have his employment reviewed.
  • Until the investigation is completed & concerns proven without doubts, the confidentiality of the person who is the subject of the report will be safeguarded.
  • ECRU will notify the reporting employee of the outcome of its findings within 30 days of receipt of report.

Conclusion

The Board of Directors of GDEX is strongly committed in having a strong whistleblowing culture and will, through the ECRU, regularly assess the company internal whistleblowing system.

GDEX employees are encouraged to provide suggestions and feedback on improving the company whistleblowing system.

GDEX whistleblowing procedure will be part of the annual cycle of monitoring compliance related to Corporate Governance. Annually ERCU will present an evaluation report of its activities and findings to the Audit Committee of the Board of Directors without naming the reporting employees as guaranteed under the company WBPP.