Objective

At BROADFIELD HOLDINGS, we uphold the highest standards of ethical, moral, and legal business conduct. To ensure that these standards are met, we have implemented the Whistle-Blowing Policy (“Policy”). This Policy serves as a platform for employees and other stakeholders to raise concerns and report any instances of work malpractices or improper conduct within the organization, with the assurance that they will be protected from retaliation or victimization for coming forward in good faith.

The implementation of the whistle-blowing policy enables BROADFIELD HOLDINGS Management to address issues promptly and proactively within the organization, without the adverse consequences associated with public disclosure, such as damage to the organization’s image or reputation, financial strain, and loss of stakeholders’ trust. Through this program, employees are encouraged to confidentially report any concerns related to illegal, unethical, or improper business conduct occurring within the organization. By doing so, employees assist the organization in monitoring and identifying instances of such conduct that may otherwise go unnoticed through regular processes or transactions.

Scope

this policy is designed to make it easy for employees to report any improper conduct, whether it is misconduct or a criminal offense, through internal channels. The following are examples of misconduct or criminal offenses that may be reported under this policy:

• Fraud
• Bribery
• Corruption
• Abuse of Power
• Conflict of interest
• Misuse of the company’s assets and funds
• Non-compliance with policies and procedures

The above list is not exhaustive, and it includes any act or omission that, if proven, would constitute an act of misconduct or a criminal offense under applicable laws. This policy is intended to allow employees to raise concerns in an independent and unbiased manner. Employees are not required to prove their cases, but they must provide sufficient information for management to take appropriate action.

POLICY

Confidentiality

• The identity of the whistleblower will be kept confidential to the greatest extent possible. Only the BROADFIELD HOLDINGS ABC Committee and the MD/CEO who receives the concern will know the whistleblower’s identity.
• The whistleblower’s identity will not be revealed unless required by law or with their permission.
• All concerns raised will be treated with the utmost confidentiality.

Protection Accorded to Whistleblower

Whistleblowers will be protected from retaliation to the greatest extent possible. Their identity will be kept confidential, and they will not be subject to any adverse or detrimental actions for reporting improper conduct, as long as the disclosure is made in good faith. This protection applies even if the investigation later reveals that the whistleblower was mistaken.

Retaliation, victimization, or intimidation against any whistleblower who makes a report in good faith is a serious violation of this policy and will be met with serious disciplinary action.

Anonymous disclosures will not be entertained, but the company may still investigate them if the evidence provided is credible.

Response

All concerns raised will be carefully reviewed by BROADFIELD HOLDINGS’s ABC Committee. If necessary, they will be thoroughly investigated. Appropriate corrective action will be taken if the investigation warrants it.

The whistleblower will be notified in writing upon receipt of the concern and will then be verbally updated on the status of the investigation or resolution of the concern by the ABC Committee that received the concern.

Untrue Allegations

If a whistleblower raises a concern in good faith but is not confirmed by the investigation, they will not be subject to any disciplinary action. However, if a person raises a concern frivolously, maliciously, or for personal gain, disciplinary action may be taken against them.

Anonymous Reporting

BROADFIELD HOLDINGS doesn’t entertain anonymous reporting. However, the ABC Committee or the Management will initiate an investigation to look into the concerns if it meets any of the following conditions:

• The allegation is supported by proper evidence such as photographs /documents.
• Concern raised is related to the process rather than the individuals.
• The concern results in financial loss or impacting the image/reputation of the organization.
• As requested by the Chairman /Director

REPORTING

Disclosure of improper conduct can be made to any of the following reporting channels:

• Email to integrity@broadfield.com.my
• Online submission via Reporting of Concern Form at BROADFIELD HOLDINGS’s website.
• By mail in a sealed envelope marked “Strictly Private and Confidential” to:

Anti-Bribery & Corruption Committee (Click here for full Anti-Bribery & Corruption Statement)

BROADFIELD HOLDINGS SDN. BHD.

D6-3A-3A, Bangunan Perdagangan D6,

801 Jalan Sentul, 51000 Kuala Lumpur.

Meet any of the ABC Committee Members or the MD/CEO in person.

Call the Whistleblowing hotline at +603 4051 0481

If the disclosure is made verbally, it must be followed by a report in writing to ensure that there is a clear

understanding about the issues raised.