Lot 3304 Batu 24 1/2 Jalan Kulai - Air Hitam

81000 Kulai, Johor Malaysia

Tel: +607-6522288       Fax: +607-6522299


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Thursday, 22 February 2018

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Whistleblowing Policy


 SCGM BHD (Company No. 779028 H)





This whistleblowing policy is designed to encourage employees of SCGM BHD (“the Company” or “SCGM” together with its subsidiaries, the “Group”), and related third parties (e.g. customers, suppliers, etc., who deal with the Company) (“Third Parties”) to raise concerns, in confidence, about misconduct, malpractice or irregularities in any matters related to the Company.


Responsibility to Report




The Code of Ethics of SCGM (“COE”) provides the guiding principles for all Board members and employees to take the right action, behave with integrity and honesty, treat people fairly, respect diversity, obey all laws, accept accountability, communicate openly, and always behave in a way that is beyond reproach.




Under the COE, employees are required to promptly alert their supervisor or higher management of business and work-related situations that could be damaging to SCGM or cause harm to others such as emergencies, crimes, accidents, irregularities or other unexpected events; and to take reasonable action to prevent damage or harm. Employees could be in breach of the COE if they assist or authorize others in activities that breach the COE, conceal or fail to report any known or suspected breaches by others. Employees and Third Parties may also have a duty to report corruption to the authorities if required to do so by local regulations.








Persons making genuine and appropriate complaints under this policy are assured of fair treatment. In addition, SCGM Group’s employees are also assured of protection against unfair dismissal, victimization or unwarranted disciplinary action, even if the concerns raised turned out to be unsubstantiated. SCGM Group reserves the right to take appropriate actions against anyone (employees or Third Parties) who initiates or threatens to initiate retaliation against those who have raised concerns under this policy. In particular, employees who initiate or threaten retaliation will be subject to disciplinary actions under the COE, which may include summary dismissal. Management will support all employees and encourage them to raise concerns without fear of reprisals.








SCGM Group will make every effort, within its capacity to do so, to keep a Whistleblower’s identity confidential. SCGM Group will endeavor to advise a Whistleblower in advance if his or her identity may become apparent or need to be disclosed. Should an investigation lead to a criminal prosecution, it may become necessary for a Whistleblower to provide evidence or be interviewed by the relevant authorities.



Types of Misconduct, Malpractice and Irregularity




It is not possible to give an exhaustive list of the activities that constitute misconduct, malpractice or irregularity covered by this policy. For example, SCGM Group expects all employees to observe and apply the COE principles in the conduct of SCGM Group’s business. Employee behavior that is not in line with COE principles could constitute a misconduct, malpractice, or irregularity that should be reported. The principles of COE relate to :





integrity and honesty






avoiding conflicts of interest






safety, health and environment



compliance with financial controls and reporting requirements



moderation in gifts



compliance with laws and regulations



protecting our information, records and assets



compliance with the code and obligation to report


Reporting and Investigations





Reporting Channels






For employees, they may prefer to have an initial discussion with his/her manager or Human Resources Manager (“HRM”). However, the HRM must in turn report any potential or actual misconducts, malpractices or irregularities to the Managing Director (“MD”). If employee feels uncomfortable doing this (e.g., his/her line manager has declined to handle his/her case or it is the line manager who is the subject of the report), then the employee can contact MD directly. Business partners, suppliers and Third Parties are encouraged to report directly to MD.


However, if it involves sensitive issue that may not convenient to convey to MD, then employee or Third Party can contact the Independent Non-Executive Director.






Reports and Supporting Documentation






While SCGM Group does not expect the Whistleblower to have absolute proof or evidence of the misconducts, malpractices or irregularities reported. The report should show the reasons for the concerns and full disclosure of any relevant details and supporting documentation. If he/she makes a report in good faith then, even if it is not confirmed by any subsequent investigation, the Whistleblower’s concerns would be valued and appreciated.






All complaints will be treated strictly private and confidential.









Every report or complaint received will be assessed.


If there is sufficient evidence to suggest that a case of possible criminal offence or corruption exists, the matter will be reported and addressed to the relevant authority accordingly.


A full report on the investigations conducted without revealing the identity of the Whistleblower. For confirmed cases of COE violations, the normal process is for the HRM to determine what disciplinary action is appropriate and make a recommendation to the MD for final decision.





False Reports




If a Whistleblower makes a false report maliciously, with an ulterior motive, or for personal gain, SCGM Group reserves the right to take appropriate actions.




Anonymous Reports




As SCGM Group takes reporting of misconducts, malpractices, and irregularities seriously and wants to conduct warranted investigations of both potential and actual violations, it is preferred that these reports are not made anonymously. However, it is recognized that for any number of reasons, employees or Third Parties may not feel comfortable reporting potential violations directly to MD. In these cases, anonymous reports may be submitted to any one of the Independent Non-Executive Director.




Responsibility for Implementation and Review of Policy




This policy has been approved and adopted by the Board of the Company. The Audit Committee has been delegated overall responsibility for implementation, monitoring and periodic review of this policy and any matter raised must be put forward to the Board for approval.












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