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PROCEDURE FOR WHISTLEBLOWER POLICY

Policy Statement

PR1MA Corporation Malaysia (“PR1MA” or the “Corporation”) and its subsidiaries (the “Group”) are committed to the values of transparency, integrity, impartiality and accountability in the conduct of its business and affairs. PR1MA expects wrongdoings such as fraud, corruption, serious financial impropriety and gross mismanagement to be reported and it facilitates this through internal mechanisms.

Objective

This policy is designed to facilitate the making of a disclosure as early as possible any wrongdoings, to protect a whistleblower from reprisal as a direct consequence of making a disclosure and to treat both the whistleblower and alleged wrongdoer fairly.

Scope

This policy applies to any PR1MA’s employees or people performing services for PR1MA or members of the public who has knowledge or aware of any wrongdoings committed or about to be committed within PR1MA Corporation Malaysia and its subsidiaries is encouraged to make disclosure by following the procedures as stated in this document.

Reporting Channels

Disclosure can be made to ANY of the following reporting channels, in strict confidential manner:

  • Email to whistle.blowing@pr1ma.my; or
  • E-Form provided at www.pr1ma.my/whistleblowing/E-Form; or
  • In writing and forward in a sealed envelope to the Chairman of the Audit & Risk Management Committee (ARMC), 7th Floor, Block F, No. 2, Jalan PJU 1A/7A, Oasis Square, Oasis Damansara, 47301 Petaling Jaya, Selangor. On the envelope shall label with a legend such as “To be opened by the Chairman of Audit & Risk Management Committee only, in the presence of the Company Secretary.  Whistleblower Report Form is provided at www.pr1ma.my/whistleblowing/whistleblowerreportform

PR1MA employee should first consult or raise their concerns with their immediate supervisors or heads or, when necessary, the CEO. If their complaints or concerns remain unsolved, they can use ANY of the above mentioned reporting channels.

Disclosure of Identity

A disclosure shall include at least the following particulars:

  • Name
  • Designation
  • Name of Employer (if not an employee of PR1MA)
  • Current address
  • Contact Number
  • Reason for his/her concerns
  • Particular of witnesses (if any)
  • Documentary evidence (if any)

The personal details will be kept confidential.

PR1MA management will not entertain any cases/complaints without whistleblower details as prescribed above.

Type of Wrongdoings

A disclosure may be made if it relates to one or more of the following wrongdoings:

  • acceptance of favor;
  • corruption or fraud;
  • criminal offence;
  • misuse of PR1MA’s funds or assets;
  • gross mismanagement within PR1MA;
  • serious financial irregularity or impropriety within PR1MA;
  • serious breach of PR1MA's Code of Ethics;
  • an Act or omission which creates a substantial or specific danger to the lives, health, or safety of PR1MA’s employees, the public or the environment;
  • failure to comply within the provisions of other Acts of Parliament where the wrongdoer, knowingly, disregards or does not comply with such provisions; and
  • knowingly directing or advising a person to commit any of the above wrongdoings.

Protection to Whistleblower

The whistleblower who has disclosed a wrongdoing in good faith and based on reasonable grounds will be protected from reprisal within PR1MA as a direct consequence of his/ her disclosure and the whistleblower’s identity will be protected.

Consequences of Wrongful Disclosure

If the whistleblower has or is found to have made wrongful disclosure:

  • If employee of PR1MA, disciplinary action will be taken by Human Resource Department.
  • If not employee of PR1MA, PR1MA Management may refer to relevant authority i.e Police for further action.

Notification on the Outcome of the Disclosure

The whistleblower will be informed of the status of his/ her disclosure matter as far as reasonably practicable.

Whistleblowing Procedure Chart