WHISTLE BLOWING POLICY


1.0 INTRODUCTION

1.1 Timberwell Berhad ("TWB" or "the Company") is committed to achieving and maintaining high standards of integrity, accountability and ethical behavior in the conducts of its businesses and operations.

1.2 In order to achieve the standards, the Board of TWB has developed this Whistleblowing Policy ("Policy") to provide a structured reporting channel and guidance to all employees and stakeholders (i.e. shareholders / suppliers / customers) to report genuine concerns about unethical behaviour, malpractices, illegal acts or failure to comply with regulatory requirements without fear of reprisal should they act in good faith when reporting such concerns.

1.3 TWB views any harassments or retaliations in any form or manner against genuine whistle blower seriously and will treat such action as gross misconduct, which if proven, may lead to dismissal.

1.4 The policy and procedures is applicable to all companies within TWB Group.


2.0 WHISTLE SCOPE

2.1 Whistle Blowing is a specific means by which an employee or stakeholder can report or disclose through established channels, concerns about unethical behaviour, malpractices, illegal acts or failure to comply with regulatory requirements that is taking place / has taken place / may take place in the future.

2.2 Only genuine concerns should be reported under Whistle Blowing procedures. This report should be made in good faith with a reasonable belief that the information and any allegation in it are substantially true, and the report is not made for personal gain. Malicious and false allegations will be viewed seriously and treated as a gross misconduct and if proven may lead to dismissal.

2.3 The following shall constitute "Improper Conduct", including, but not limited, under this Policy:


3.0 PROCEDURES

3.1 Any concern should be raised with immediate superior. If for any reason, it is believed that this is not possible or appropriate, then the concern should be reported to Chief Executive Officer (using the attached form as per Appendix 1). Channel of reporting to Chief Executive Officer are:


Name : Chief Executive Officer
Email : enquiry@timwell.com.my
Telephone : +6088 222 190
Mail : Mark Strictly Confidential

Timberwell Berhad
2nd Floor, Wisma BSN Sabah
Jalan Kemajuan, Karamunsing
88000 Kota Kinabalu, Sabah

Attention: Chief Executive Officer


3.2 In the case where reporting to management is a concern, then the report should be made to the Chairman of Audit Committee. Channel of reporting (using the attached form as per Appendix 1) to the Chairman of Audit Committee.

Mail : Mark Strictly Confidential

Timberwell Berhad
2nd Floor, Wisma BSN Sabah
Jalan Kemajuan, Karamunsing
88000 Kota Kinabalu, Sabah

Attention : Chairman – Audit Committee


4.0 ACTION

4.1 All reports will be investigated promptly by the person receiving the report. If required, he can obtain assistance from other resources within the Group. The progress of investigation will be reported to the Audit Committee no later than at the next scheduled meeting.

4.2 Reports received anonymously will be treated as confidential.

4.3 The person making anonymous report will be advised that maintaining anonymity may hinder an investigation. Irrespective of this, anonymity will be maintained as long as it’s permitted by law or the person making the report indicates that he no longer wishes to remain anonymous.

4.4 Upon completion of investigation, appropriate course of action will be recommended to the Audit Committee for their deliberation. Decision taken by the Audit Committee will be implemented immediately.

4.5 Where possible, steps will also be implemented to prevent similar situation arising.


5.0 FURTHER ACTION

5.1 If for any reason, the person making the report is not satisfied with the way his report had been dealt with, he can escalate his report to the Chairman of Audit Committee. Channel of reporting (using the attached form as per Appendix 1) to the Chairman of Audit Committee.

Mail : Mark Strictly Confidential

Timberwell Berhad
2nd Floor, Wisma BSN Sabah
Jalan Kemajuan, Karamunsing
88000 Kota Kinabalu, Sabah

Attention : Chairman – Audit Committee

5.2 Chairman of Audit Committee will deliberate the report with his Committee members and decide on the appropriate course of action.


6.0 REVIEW OF THIS POLICY

The Board of Directors or Audit Committee can modify this Policy unilaterally at any time without notice. Modification may be necessary, among other reasons, to maintain compliance with laws and regulation and / or accommodate organisational changes within the Company or TWB Group. However, the modification made shall be effective after the same is circulated to employees in writing or electronically.