Whistleblowing Policy
1. INTRODUCTION
 
Wentel Engineering Holdings Berhad (“WEHB” or “the Company”) and its subsidiary(ies) (“the Group”) are committed to the highest standard of corporate governance and business integrity.

In recognising the above mentioned values, the Group provides an avenue for all of the employees of the Group and the members of the public to raise their concerns or disclose any improper conduct within the Group and to also take appropriate action to resolve them effectively.
 
2. OBJECTIVE
 
The intended objectives of this policy are:
 
  1. To encourage and develop a culture of openness, accountability and integrity.
  2. To provide avenues for the stakeholders to raise genuine concerns or allegation through the appropriate channels upon discovery of any possible misconduct.
  3. To ensure the protection to an individual who reports the concern or allegation in good faith in accordance with the procedures.
  4. To enable Management to be informed at an early stage about acts of misconduct.
 
3. SCOPE OF THE POLICY
 
This Policy applies to the Group.
 
All Directors and employees of the Group working at all levels and grades, shareholders and any third parties associated with the Group, which may include but not limited to customers, suppliers, contractors, agents, consultants, outsourced personnel, distributors, advisers, government and public bodies including their advisors, representatives and officials are encouraged to report or disclose through established channels, concerns about any violations of the Code of Ethics and Conduct of the Group, including, but not limited to the following:-
 
  1. Fraud or Dishonesty;
  2. Breaches of Policies, Procedures and applicable laws and regulations;
  3. Bribery or Corruption or blackmail;
  4. Abuse of Power;
  5. Conflict of Interest;
  6. Insider Trading;
  7. Criminal breach of trust;
  8. Sexual Harassment;
  9. Criminal Offences;
  10. Misuse of confidential information; and/or
  11. Concealment of any, or a combination, of the above.
 
This Policy does not apply to grievances concerning employee’s terms of employment or other aspects of concerns or complaints within the scope of the Staff/Employment Policy.
 
4. ACTING IN GOOD FAITH
 
The Group expects all parties to act in good faith and have a reasonable belief that the information and any allegations in it, are sustainably true and not acting for personal gain. Any anonymous whistleblower will not be entertained. However, the Group reserves its right to investigate any anonymous disclosure. If allegations are proven to be malicious, parties responsible may be subject to appropriate action, up to and including legal action, where applicable.
 
5. CONFIDENTIALITY
 
The identity of whistle blower will be kept confidential. Consent of whistle blower will be sought should there be a need to disclose identity for investigation purposes.
 
6. PROTECTION
 
The Group assures the whistle blower who raises issues of concern that he/she will be protected from interference with his/her lawful employment or livelihood, including discrimination, discharge, demotion, suspension, disadvantage, termination or adverse treatment in relation to his/her employment, career, profession, trade or business or the taking of disciplinary action as a result of his/her reporting, provided the report is made in good faith and without malice. Any party that retaliates, including harassment and victimization, against whistle blower who has reported allegations in good faith may be subject to appropriate action, up to and including legal action, where applicable.
 
7. REVOCATION OF POLICY
 
The protection stated above shall be revoked by the Group if:
 
  1. The whistle blower himself/herself has participated in the improper conduct, wrongdoings, corruption, fraud and/or abuse;
  2. The whistle blower made his/her disclosure without good faith;
  3. The disclosure was frivolous or vexatious; or
  4. The disclosure was made with the intention or motive to avoid dismissal or other disciplinary action against the whistle blower himself/herself.
 
8. ACTION
 
The Chairman/Managing Director (“MD”)/Executive Director (“ED”) of the Company who receives the complaint shall maintain all complaints received, tracking their receipt, investigation and resolution. Each report shall be screened to assess its reliability and whether there is sufficient information to warrant an investigation. All reports will be investigated promptly by the person receiving the report or disclosure. If required, assistance from other resources within the Group can be sought. Upon completion of the investigation, an appropriate course of action will be recommended to the Audit and Risk Management Committee of the Company (“ARMC”) for their deliberation. The decision taken by the ARMC will be implemented immediately. Where possible, steps will also be implemented to prevent similar situations from arising. The ARMC shall then update the Board of Directors on the report of the status and outcome of the investigation and whether the effectiveness of the implementation of this policy requires their attention and approval.
 
9. WHISTLE BLOWING REQUIREMENTS
 
The reports should be submitted together with the following information:-
 
  1. Details of the whistle blower (strongly encouraged, even though whistle blower may choose to remain anonymous);
  2. Type of activity/conduct;
  3. The reason for the concerns;
  4. Details of suspected personnel involved;
  5. Details of the incident (including date, time and location of incident); and
  6. Any supporting/documentary of all factual evidence
 
10. REVERTING TO COMPLAINANT
 
The whistle blower will be informed on the progress and status of the investigation, however the Group reserves the right not to inform the whistle blower of the precise action plan and/or the outcome of the investigation as this may infringe a duty of confidentiality owed to someone else.
 
11. WHISTLEBLOWING CHANNEL
 
The established channels for whistleblowing reporting are as follows:

Any concern should be raised with the immediate superior. If for any reason, it is believed that reporting to Management is not possible or appropriate, then the concern should be reported to the ARMC Chairman. The channel of reporting is as follows:
 
By Mail:   Strictly Confidential
Wentel Engineering Holdings Berhad
No. 11, Jalan Gagah,
Kawasan Perindustrian Larkin,
80350 Johor Bahru,
Johor.
 
    Attention: The Audit and Risk Management Committee Chairperson
 
OR
 
By Email: whistleblowing@wenteleng.com
 
12. REVIEW OF THE POLICY
 
This Policy will be reviewed at least once every three (3) years to ensure its effectiveness and consistency with the governing legislation, the Board’s objectives, responsibilities and standards of corporate governance and regulatory requirements, or more frequently should there be material changes to the said legislation and regulations or circumstance of the business, if any.
 
13. BOARD APPROVAL
 
This Policy (Version No. 1) was reviewed and approved by the Board of Directors of the Company on 22 June 2023.
 
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