Policy

Effective Date: 8 June 2016

MALAYSIA AIRPORTS HOLDINGS BERHAD WHISTLEBLOWING POLICY

1. Policy Statement

   Malaysia Airports Holdings Berhad (“MAHB” or “the Company”) is committed to the highest standards of honesty, openness and accountability. In line with that commitment we expect employees, and others that we deal with, who have genuine concerns about any aspect of MAHB’s operations to come forward and voice those concerns.

   The act of raising such concerns is called whistleblowing. Whistleblowing can be defined as raising concerns about misconduct within an organisation or within an independent structure associated with it.

   The Whistleblowing Policy (“policy”) aims to:

   1. encourage employees and external parties to feel confident in raising genuine concerns and to question and act upon concerns about practice.
   2. provide avenues for employees and external parties to raise those concerns and receive feedback on any action taken.
   3. reassure employees and external parties that they will be protected from possible reprisals or victimisation for whistleblowing in good faith.

    

2. Scope
   1. The policy applies to all employees of MAHB Group of Companies (“the Group”) and external parties who have business relationships with the Group.
   2. The scope of this policy covers possible improprieties listed below:
      1. Commission of fraud, bribery and/or corruption
      2. Unauthorised use of Company’s money, properties and/or facilities
      3. Exposure of Company’s properties, facilities and/or staff to the risks of safety and security
      4. Abuse of position
      5. Involvement in unlawful act
      6. Failure to meet Professional Standards
      7. Negligence/malpractice
      8. Disclosure of Company’s information without proper authorisation
   3. The above list is not exhaustive and includes any act or omissions, which if proven, will constitute act of misconduct under MAHB Code of Ethics or any criminal offence under relevant legislations in force.
   4. The policy however, does not cover:
      1. False concerns
      2. Defaming concerns
      3. Concerns with no basis or insufficient evidence
      4. Malicious concerns
3. Responsibility
   1. The overall responsibility for the maintenance and operation of this policy sits with the Whistleblowing Independent Committee (“WIC”) which is specifically set-up to look into concerns raised by employees and external parties.
   2. All concerns raised and the outcomes (in an anonymous format) will be reported as necessary to Board Audit Committee.
4. Policy
   1. Confidentiality
      1. The identity of the Whistleblower is only known by the WIC member or the WIC Secretariat who receives the concern.
      2. The Whistleblower’s identity will not be revealed unless it is required by the law or with his/her permission.
      3. All concerns raised will be treated in strictest confidence.
   2. Protection Accorded to Whistleblower
      1. If the Whistleblower acts in good faith and responsibly in his/her reporting, he/she will be protected against any form of victimisation, retribution or retaliation within the Group to the extent reasonably practicable.
      2. However, protection accorded under this policy will be revoked if:
         1. the Whistleblower participated in the improper conduct disclosed;
         2. the Whistleblower will fully discloses false statements;
         3. the disclosure made is frivolous or malicious; or
         4. the disclosure is made with the motive of avoiding dismissal or other disciplinary action.
      3. MAHB will not tolerate any harassment, victimisation or retaliation against the Whistleblower under the policy. Anyone who retaliates against the Whistleblower will be subjected to disciplinary action up to and including termination of employment.
      4. If the Whistleblower feels that discriminatory action has been exercised against him/her, he/she must immediately contact any WIC member or the WIC Secretariat to file his/her apprehension.
   3. MAHB Response
      1. All concerns raised will be given due consideration by WIC and thoroughly investigated if the need arises. Appropriate corrective action will be taken if warranted by the investigation.
      2. The Whistleblower will be informed in writing upon receipt of concern and subsequently verbally updated of the status of the investigation or resolution of the concern by the WIC member who received the concern.
   4. Untrue Allegations
      1. If the Whistleblower raises a concern in good faith, but it is not confirmed by the investigation, no action will be taken against him/her. If, however, someone raises a concern frivolously, maliciously or for personal gain, disciplinary action may be taken against the person.
   5. Anonymous Reporting

      As a matter of principle MAHB does not entertain anonymous reporting. However, the Management or the WIC may initiate an investigation to look into concern(s) raised via an anonymous letter if one of the following conditions is met:

      1. the letter is supported by evidences such as photographs/documents.
      2. concern raised is relating to process rather than regarding individual(s).
      3. the concern results in financial loss/negative image or reputation to the Group.
      4. as requested by the Chairman or any member of MAHB Board.
5. How to Raise a Concern
   1. The Whistleblower may raise his/her concern to any WIC member or the WIC Secretariat by either calling or visiting the WIC member or the WIC Secretariat. Alternatively, WIC members can also be contacted via the respective member’s dedicated WIC email account.
   2. Whistleblowers are encouraged to raise concerns promptly, preferably in writing, giving as much information as possible, such as relevant background, names, dates, places and the reason for their concern. The earlier a concern is raised, the easier it will be to take effective action.