INTRODUCTION

Grand-Flo Berhad (“Grand-Flo” or “Company”) and its subsidiaries (“the Group”) are committed to the highest standard of corporate governance and business integrity.

In recognizing the above mentioned values, the Group provides avenue for all employees of the Group and members of the public to raise concerns or disclose any improper conduct within the Group and to take appropriate action to resolve them effectively.

OBJECTIVE
The intended objectives of this policy are:

i. To provide avenues for employees to raise genuine concerns or allegation through the appropriate channels upon discovery of possible misconduct
ii. To ensure the protection to individual who reports the concern or allegation in good faith in accordance with the procedure
iii. To encourage and develop a culture of openness, accountability and integrity
iv. To enable Management to be informed at an early stage about acts of misconduct.

SCOPE OF THE POLICY
This policy is designed to facilitate the whistle blower 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 fraud, bribery, sexual harassment, criminal breach of trust, conflict of interest, misuse of confidential information or other acts of wrong doing.

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 into 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.

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.

PROTECTION
The Group assures the whistleblower who raises issues of concern that he/she will be protected from any adverse impact on their employment or relationship with the Group as a result of his/her reporting, provided the report is made in good faith and without malice. Any party that retaliates against whistleblower who has reported allegations in good faith may be subject to appropriate action, up to and including legal action, where applicable.

ACTION
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 investigation, appropriate course of action will be recommended to the Audit Committee of the Company (“AC”) for their deliberation. Decision taken by the AC will be implemented immediately. Where possible, steps will also be implemented to prevent similar situation arising.

REVERTING TO COMPLAINANT

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 owned to someone else.

WHISTLE BLOWING CHANNEL
The established channels for whistle blowing reporting are as follows:

a) Any concern should be raised with the immediate superior. If for any reason, it is believed that this is not possible or appropriate, then the concern should be reported to the Group Managing Director /Group President (“GMD/GP”). The channel of reporting to the GMD/GP is as follows:

By Email :derricktan@grand-flo.com

By Mail: Strictly Confidential

Grand-Flo Berhad

3-5, Block D2, Jalan PJU 1/39, Dataran Prima,

47301 Petaling Jaya, Selangor, 
Malaysia.

Attention: The Group Managing Director/Group President

b) If for any reason, it is believed that reporting to management is a concern or not possible or appropriate, then the concern should be reported to the Outsourced Internal Auditors of the Group. The channel of reporting to the Outsourced Internal Auditors is as follows:

By Email :qwestconsultants@yahoo.com

By Mail:
Strictly Confidential

Qwest Corporate Consultants Sdn. Bhd.

Unit 1-3-3, No. 1, Jalan P. Ramlee,

10460 Penang,
Malaysia.

Attention: The Chief Internal Auditor

DISCLAIMER
Grand-Flo reserves the right to amend this policy from time to time.