1. Introduction
    1.1 In line with good corporate governance practices and with the introduction of the Whistleblower Protection Act 2010, the Board and Management of Eco-Shop Marketing Sdn Bhd (“the Company”) and its extended companies (“Eco extended group of companies”) has put in place a Whistleblowing Policy to report any suspected and/or known misconduct, wrongdoings, corruption and instances of fraud on the part of employees, management, directors, suppliers and vendors in particular with respect of their obligation to the Company and Eco extended group of companies’ interest.

  2. Objectives
    2.1     The objective of this policy is to provide an avenue for all employees of the Company and Eco extended group of companies and any third party including external parties who have business dealings with the Company and Eco extended group of companies to report any suspected and/or known improper conduct and wrongdoings in accordance with the procedures as provided under this policy and to provide protection for employees and any third parties including external parties who report such allegations.

  3. Reporting Improper Conduct
    3.1 An improper conduct is any act of omission which can be defined to be any suspected and/or known wrongdoings, which if proven, will constitute an act of misconduct (“Improper Conduct”), that can be reported using the available channels, on the following incidents as below:

    • Fraud;
    • Misappropriation of assets;
    • Sexual Harassment;
    • Criminal breach of trust;
    • Bribery and corruption;
    • Falsification of documents;
    • Unauthorised transactions;
    • Undisclosed conflicts of interest;
    • Acts or omissions which are deemed to be against the interest of the Company, laws, regulations or public policies;
    • Non-compliance with the ABAC Policy;
    • Misuse of confidential information; or
    • Health and safety risks, including risks to the public as well as other employees.

  4. Confidentiality and Anonymity
    4.1 All whistleblowing reports are strictly confidential and or anonymous and every effort is made not to reveal the identity of the whistleblower’s identity, if so wish, except where:
    a) the disclosure of identity is required by law;
    b) the disclosure is required for purposes of investigation of making a report to the relevant authorities;
    c) the disclosure is required for legal or audit professionals in order to obtain professional advice; or
    d) where such information already in the public domain.

    4.2 The Company gives assurance that the identity of the whistleblower will only be known by a few top managements on a “need to know basis” and the outcome of any investigation will be disclosed to the whistleblower. This is to encourage and give confidence to the whistleblower that the complaint will be investigated and all reports will be strictly made confidential.

  5. Acting in Good Faith
    5.1 All whistleblowing reports shall be made in good faith with reasonable belief that the information and allegation(s) is true and not frivolous/malicious and not for personal gain, otherwise, the Company will take appropriate action against the parti(es) concerned including disciplinary action and/or legal action, where applicable.

    5.2 Disciplinary action, including summary dismissal, may be taken against any employee found to be making reports or allegations which is untrue with malicious intent or in bad faith.

  6. Protection of Whistleblower
    6.1 The policy provides assurance that the whistleblower, if an employee of the Company, shall be protected against reprisals or retaliation and immunity from disciplinary action, provided that:
    a) only genuine concerns are reported, and the report is made in good faith with a reasonable belief that the information of any allegation in it are substantially true, and the whistleblower does not provide false or misleading information knowingly, negligently or recklessly in the report;
    b) the disclosure is not made with malicious intent or ill will;
    c) the disclosure is not frivolous or vexatious; and
    d) the report is not made for personal gain or agenda.
    (a) to (d) collectively shall be referred to as “Protection”).

    6.2 The Company trust that every whistleblower must conduct themselves with high integrity and responsibility. To establish a sound relationship of trust, individuals who make disclosures are encouraged to identify themselves and their contact (phone number/email). This is especially so when detail information is required. Whenever necessary, the whistleblower may be required to stand as a witness for the Company for the appropriate disciplinary action to be effective.
    All information received will be treated with strictest confidentiality.

    6.3 The Protection stated above shall be revoked by the Company if:
    a) the whistleblower himself has participated in the improper conduct, wrongdoings, corruption, fraud, waste and/or abuse;
    b) the whistleblower wilfully or maliciously made his disclosure, knowing or believing the information is false or untrue;
    c) the disclosure is frivolous or vexatious;
    d) the disclosure is made with the intention or motive to avoid dismissal or other disciplinary action;
    e) the disclosure principally involves questioning the merits of government policy, including policy of a public body; or
    f) the whistleblower, in the course of making the disclosure or providing further information, commits an offence under the Whistleblower Protection Act.

  7. Reporting Channel
    7.1 Any party who encounters actual or suspected Improper Conduct, may report their concerns using the attached “” as per Appendix I.

    Report may be made through any of the designated reporting channels below:
    • i) via email hotline:
    • ii) via letter addressed to:
      Compliance Department
      Eco-Shop Marketing Sdn Bhd
      Lot 3913 – 3914, Kampung Sungai Siput
      85200 Jementah, Segamat, Johor

    7.2 The Company’s employee(s) may also choose to report their concerns to their direct superior, or to the human resource director, or if such personal is not available, to the HR manager of the HR Department through the following channels below:
    • i) via email hotline:
    • ii) via letter addressed to:
      Human Resources Department
      (Attn: HR Director)
      Eco-Shop Marketing Sdn Bhd Lot 3913 – 3914, Kampung Sungai Siput
      85200 Jementah, Segamat, Johor .