1. POLICY STATEMENT

   1. EcoWorld conducts its business based on principles of fairness, honesty, openness, decency, integrity and respect. EcoWorld strives to foster and provide an environment where Whistleblowers can act appropriately without fear of reprisal or retaliation.
   2. This Policy provides guidance for Whistleblowers who have knowledge of any Improper Conduct to come forward and report such information in good faith.
   3. Procedures are also incorporated in this policy to provide protection for Whistleblowers from reprisal or retaliation.
   4. For the avoidance of doubt, the protection afforded to Whistleblowers under this Policy is internal protection provided by EcoWorld and is separate and distinct from any statutory protection that may be available under the Whistleblower Protection Act 2010 [Act 711], as amended from time to time (“Act 711“). Nothing in this Policy limits any person’s right to make a disclosure to an enforcement agency in accordance with Act 711 or any other applicable law.

2. OBJECTIVE

   1. The main objectives of this Policy are:
      1. to provide a confidential avenue for Whistleblowers to report any Improper Conduct and set out the procedures to deal with such reports;
      2. to enable EcoWorld to be informed at an early stage about any Improper Conduct;
      3. to assure Whistleblowers that they will be protected from reprisal or retaliation as a consequence of reporting any Improper Conduct in good faith; and
      4. to develop a culture of openness, accountability and integrity.

3. DEFINITIONS

   1. “Act 711” means the Whistleblower Protection Act 2010 [Act 711], as amended from time to time.
   2. “EcoWorld” means Eco World Development Group Berhad, its subsidiaries, joint venture companies and associated companies, and other EcoWorld branded entities that adopt this Policy.
   3. “Improper Conduct” means any conduct which if proved, constitutes a disciplinary offence or a criminal offence, which shall include but not limited to the following:
      1. fraud, corruption, bribery, theft, embezzlement or blackmail;
      2. forgery or alteration of any document or accounts;
      3. impropriety in handling or reporting of money or financial transactions;
      4. financial malpractice or irregularities;
      5. profiteering as a result of insider knowledge;
      6. impropriety in tender and procurement activities;
      7. abuse of power and position for personal gain;
      8. discrimination, bullying and harassment (including sexual harassment);
      9. failure to comply with applicable laws and regulations including those relating to environmental, social and governance (ESG) matters, anti-money laundering, and occupational safety and health;
      10. breach of EcoWorld’s Code of Conduct and Business Ethics and other applicable policies and procedures; and
      11. concealment of any of the above.

      However, “Improper Conduct” DOES NOT include complaints or issues relating solely to property defects, property management, common property, community issues and/or other similar operational matters which should be directed to the relevant Business Units of EcoWorld through the appropriate channels.

   4. “WBC” means EcoWorld’s internal Whistleblowing Committee, which is separate and distinct from the Whistleblower Protection Committee established under section 5A of Act 711, comprising:
      1. Ms Sar Sau Yee;
      2. Mrs Lucy Chong;
      3. Dato’ Seri Rosman Bin Mohamed; and/or
      4. such other members of the Board as the Board may appoint from time to time.
   5. “Whistleblower” means a person who has knowledge and makes a report of Improper Conduct concerning any director, officer, employee of EcoWorld or consultant, contractor, supplier or other parties having business relationship with EcoWorld in accordance with this Policy. A Whistleblower is not an investigator or finder of fact, nor do they determine the appropriate action that should be taken against the person against whom the report of Improper Conduct is made.

4. SCOPE

   1. This Policy is applicable to EcoWorld.
   2. This Policy applies to EcoWorld’s Board of Directors, senior management team and all employees. This Policy also governs consultants, contractors, suppliers and all other parties having business relationship with EcoWorld.
   3. This Policy DOES NOT apply to or change EcoWorld’s policies and procedures regarding employees’ grievances or complaints relating to their job performance, terms and conditions of employment, which will continue to be administered and reviewed by EcoWorld’s Group Talent Management Division.

5. RESPONSIBILITY

   1. Employees All employees of EcoWorld are required to acknowledge this Policy. This is to ensure that they have read and understood this Policy and are aware of EcoWorld’s commitment to a work environment free from retaliation for reporting Improper Conduct in good faith.
   2. Whistleblowers Whistleblowers must act in good faith and must not make false accusations in reporting an Improper Conduct.
   3. Person against whom the report of Improper Conduct is made The person against whom the report of Improper Conduct is made has to cooperate with the investigators fully.
   4. Investigators Investigators shall conduct the investigations promptly and confidentially. They shall be independent, unbiased in fact and appearance, and maintain the confidentiality of the Whistleblowers’ identity, unless the disclosure is required by law pursuant to an investigation.
   5. Party involved in investigation Any party (employees or otherwise) interviewed or asked to provide information must fully cooperate with the investigators. They must refrain from discussing or disclosing matters concerning the investigations.

6. REPORTING

   1. Any report of Improper Conduct under this Policy must be made in writing using the Whistleblower Reporting Form, PS-PSA-P10-01. The Whistleblower should provide all relevant information known to him/her and, to the best of his/her knowledge, ensure that all information provided is complete and accurate. The Whistleblower may be required to provide additional information and documents, if deemed necessary by the WBC.
   2. All reports of Improper Conduct under this Policy must be emailed to whistleblow_ewdgb@ecoworld.my. All such reports will be directed to the WBC for review.
   3. Nothing in clauses 6.1 and 6.2 prevents or restricts any person from making a disclosure of improper conduct directly to an enforcement agency in accordance with Act 711 or any other applicable law.

7. PROTECTION

   1. Upon receipt of a report of Improper Conduct by the WBC, the Whistleblower will be conferred protection under this Policy provided that the report is made in good faith.

   2. The protection provided in this Policy is available to the Whistleblower even if the report of Improper Conduct does not lead to any disciplinary or other action being taken against the person who is the subject of the report.

      Where a disclosure is made to an enforcement agency under Act 711, any statutory protection conferred to the whistleblower is separate and distinct from the protection provided under this Policy and shall be governed by Act 711 and any other applicable laws.

   Protection of confidential information

   3. Any person who makes or receives a report of Improper Conduct or acquires information during the course of the investigation of such report shall maintain confidentiality of such information, including the identity of the Whistleblower.
   4. In order to facilitate a smooth investigation process, the Whistleblower shall make all reasonable effort to maintain confidentiality of all confidential information, including the fact that a report has been made, the nature of the Improper Conduct and the identity of the person against whom the report of Improper Conduct is made.

   Protection against detrimental action

   5. A Whistleblower shall not be subject to any form of detrimental action, including intimidation, harassment, suspension, demotion, unfair dismissal, discrimination or any threat of such action, for reporting Improper Conduct under this Policy in good faith. A Whistleblower who believes that he/she has been subjected to any detrimental action as a result of making a report under this Policy should report the matter to the WBC.

   Revocation of Protection

   6. The protection provided to a Whistleblower under this Policy may be revoked in the following circumstances:
      1. the Whistleblower has participated in the Improper Conduct that he/she is reporting about. However, such participation will not automatically result in revocation of protection under this Policy. The WBC may determine that the protection should be maintained, in whole or in part, having regard to the circumstances of the case, the nature and extent of the Whistleblower’s participation and any findings arising from the investigation;
      2. the Whistleblower wilfully makes a material statement in the report of Improper Conduct which he/she knows or believes to be false, or does not believe to be true;
      3. the report of Improper Conduct is frivolous, malicious or vexatious;
      4. the report of Improper Conduct primarily involves questioning the merits of EcoWorld’s policies;
      5. the report of Improper Conduct is made with the intention to avoid dismissal or other disciplinary action; and
      6. the Whistleblower misuses or abuses the procedures under this Policy.

      For the avoidance of doubt, any revocation of protection under this Policy does not determine, limit or affect any statutory protection that may be available to a whistleblower under Act 711 or any other applicable law.

8. INVESTIGATION

   1. Upon receipt of a report of Improper Conduct, the WBC will provide an acknowledgement of receipt to the Whistleblower.
   2. The WBC will review each report and based on the information received and evidence available, conduct a preliminary assessment to establish whether the report has any merit and can be substantiated.
   3. If the report warrants an investigation, the WBC will open up an investigation into the matter using appropriate channels, resources and expertise and determine the appropriate action based on the findings and recommendation.

Whistleblower Reporting Form