WHISTLEBLOWING POLICY
The Company, its directors and employees are committed to observe high standards of corporate governance, integrity, honesty, openness and ethics in the conduct and operations of our business, as set forth in the Company’s Code of Ethics and Business Conduct (“Code”), including complying with all applicable laws and regulations. Acknowledging the importance of these values, this Whistleblowing Policy (“Policy”) is to enable all employees and third parties to report, amongst others, suspected and/or actual illegal or fraudulent acts, acts that endanger health and safety, misconduct and criminal offences (as defined by legislation), within or in relation to the Company.
Objective of the Policy
- To encourage employees and third parties dealing with the Company to report on any actual or suspected, illegal and/or fraudulent and/or corrupt acts, inappropriate behaviour, and improper conduct, acts or omission that may cause financial loss to the Company, or on any other matter pertaining to non-compliance of the Code. Any individual reporting a concern or making a complaint in good faith may do so without fear of dismissal, discrimination, threats, harassment or any other intimidation measures.
- To assure employees and third parties that confidentiality, including that of the identity of the individual or organisation filing the report or complaint will be maintained at all times, and valid concerns and complaints can be raised without fear of retaliation.
- To serve as a guide on how to raise concerns and complaints to the Management of the Company.
Scope of the Policy
The intent and focus of this Policy is to provide an avenue for employees and third parties to raise concerns and complaints, receive feedback on actions taken by Management on those concerns or complaints, and permit staff and third parties to respond to the actions taken. This Policy is not an alternative to established grievance or disciplinary procedures of the Company. The reporting process in respect to complaints in the instances as set forth in the Code shall be governed by this Policy, and although not exhaustive, shall include the following instances:
- Bribery and Corruption
- Misuse and Misappropriation of Company Property
- Fraudulent Acts
- Theft and Embezzlement
- Abuse of Power
- Conflicts of Interest
- Non-Compliance of Company Procedures and Policies.
Work related personal grievances such as bullying, all forms of harassment, discrimination, threats, etc. are not within the scope of this Policy, but fall within the ambit of the Company’s disciplinary or grievance procedures. If you are unsure if a complaint or report falls within this Policy or under work related personal grievances, you may seek clarification from the Human Resources Department before lodging the report or complaint.
Reporting Procedure
Who can make a report?
- Employees of the Company, whether permanent, temporary, casual, or part-time;
- Directors and officers of the Company;
- Consultants, agents, service providers, contractors, suppliers and business partners.
The Company shall endeavor to keep the identity of the individual or organisation lodging the report confidential where reasonably practicable, ensure fair treatment, and protection from any harassment or disciplinary action.
Your identity will be revealed only with your consent, or if requested by relevant authorities and/or judicial bodies. You may choose to remain anonymous when making a report by utilising a different email from your work email. For purposes of the investigation and conclusive actions, especially where there are criminal and/or corruption elements involved which may require disclosure to relevant authorities such as the Royal Malaysia Police and/or the Malaysian Anti-Corruption Commission and/or the Courts of Malaysia, it may be necessary to disclose your identity, in which case, you will be accordingly informed and contacted through your given email by the investigator from the Human Resources Department, or the relevant authorities.
Your report will be treated promptly, seriously and fairly. You may expect updates and feedback during and upon completion of internal investigations, save in instances where any feedback, may at that certain point in time, impede the investigations.
When a report should be made
A report should be made if an individual or organisation has a reasonable suspicion of wrongdoing; and/or, has witnessed, amongst others, fraudulent, corrupt and/or dishonest conduct, abuse of position or authority; acts detrimental to the interests of the Company; unsafe work practices that may create a dangerous work environment, health risks and/or abuse of Company resources.
How to make a report
A whistleblowing report must, for purposes of confidentiality, be made via the Company’s dedicated whistleblowing email address at [email protected], which will only be accessible by the Human Resources Department of the Company.
The information to be provided when filing a report are as follows:-
- Since the report will be made by email, and notwithstanding it is to be made via the dedicated email address given above, the subject of the email should make it clear the report is under this Policy, to ensure confidentiality is maintained at all times.
- Your name, address, and contact details. While a report can be made anonymously, it is recommended that these details be provided to enable the Company to provide you with the necessary advise, support, if required, and regular updates on the investigation.
- The date(s), time(s), and location(s) the wrongdoing was supposed to have occurred.
- As much details of the suspected or actual wrongdoing as you are able to provide.
- Any other information you may deem relevant.
- Any fears you may have of possible victimisation or retaliation.
Communication of Policy
This Policy shall be placed on the Company’s website www.epintl.com.
This Policy will also be incorporated into the Company’s Code of Ethics and Business Conduct and will be available for viewing at the Company’s Human Resources Department.
*The Company reserves the right to amend this Policy from time to time.*
December, 2022