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 are applicable to all companies within TWB Group.

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:

• Incidents of fraud, corruption or bribery;
• Conduct or activity which breaches any law or regulatory obligation;
• Breach of the Company’s policies, practices, procedures or other rules of conduct;
• Improprieties in matters of financial reporting;
• Misuse of confidential information; and
• Situation which pose a danger to health, safety or any individual or significant danger to the environment.

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 : 088-332455 / 332466

Mail : Mark Strictly Confidential

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

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.

5.1 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

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