WHISTLEBLOWING POLICY

1.0 INTRODUCTION

1.1 Malaysia Airports is committed to the highest standards of honesty, openness and accountability. In line with that commitment, we expect Whistleblowers who have genuine concerns about any aspect of Malaysia Airports' operations to come forward and voice those concerns.

1.2 The objective of this Policy is to provide a structured reporting channel and guidance to employees and external parties to raise their concerns about any actual, potential or suspected Improper Conduct within Malaysia Airports.

2.0 ROLES, RESPONSIBILITIES AND AUTHORITIES

2.1 The overall responsibility for the maintenance and operation of this Policy lies with the WIC which is specifically set-up to investigate concerns raised by the Whistleblower.

2.2 All concerns raised and the outcomes will be reported as necessary to the BAC.

2.3 The CID as the Secretariat to the WIC is responsible to review and update this Policy as and when there are changes in any applicable laws, code or regulations relevant to this Policy or at least once every three (3) years.

3.0 ACCESSIBILITY

The Policy can be accessed through the e-DCC under Malaysia Airports SharePoint.

4.0 SCOPE AND PURPOSE

4.1 The purpose of this Policy is to enable a Whistleblower to raise concerns about any Improper Conduct at the workplace in a way which protects their interests, and which ensures, at the same time, that instances of Improper Conduct, alleged Improper Conduct or apparent Improper Conduct are properly investigated and dealt with.

4.2 The Whistleblower will be given every opportunity to discuss or raise genuine concerns of Improper Conduct in a protected environment that the WIC and its team can investigate.

4.3 The Whistleblower must act in good faith and must have a reasonable belief that the Improper Conduct is either happening now, took place in the past, or is likely to happen in the future.

4.4 The scope of this Policy includes Improper Conduct as listed below:

i. Commission of fraud, bribery and/or corruption;
ii. Unauthorised use of Malaysia Airports' money, properties name, brand and/or facilities;
iii. Exposure of Malaysia Airports' properties, facilities and/or staff to the risks of safety and security;
iv. Abuse of power/position for gratification;
v. Involvement in unlawful act;
vi. Failure to meet Professional Standards;
vii. Negligence/malpractice;
viii. Disclosure of Malaysia Airports' information without proper authorization; or
ix. The Concern results in negative image or reputation to Malaysia Airports

4.5 The above list is not exhaustive and includes any act or omissions, which if proven, will constitute an act of misconduct under Malaysia Airports' Code of Ethics and Conduct or any criminal offence under relevant legislations in force.

4.6 Whistleblower protection under the Policy however, does not cover:

i. Concerns which are false or untrue;
ii. Concerns which are defamatory;
iii. Concerns with no basis or insufficient evidence; or
iv. Concerns which are frivolous and malicious.

5.0 POLICY

5.1 Confidentiality

i. The identity of the Whistleblower is only known by the WIC member or the WIC Secretariat who receives the Concern. It is imperative that the identity of the Whistleblower is protected, i.e. kept confidential unless otherwise required by law or for purposes of any proceedings by or against Malaysia Airports.

ii. The investigation would be carried out in strict confidentiality, by not informing the nature of the Whistleblower's Concern to any other party except the WIC member, the WIC Secretariat and CEC conducting the preliminary investigation and/or the Action Party conducting the investigation, until (or if) it becomes necessary to do so.

iii. All Concerns raised will be treated in strictest confidence.

5.2 Protection accorded to Whistleblower

i. Protection against any Detrimental Action within the Malaysia Airports to the extent reasonably practicable will be accorded by the Board Audit Committee only when the Whistleblower satisfies all the following conditions:

a. The disclosure was done in good faith;
b. The Whistleblower has reasonable grounds when raising the Concern; and
c. The Concern was communicated only to any WIC member or the WIC Secretariat.

ii. However, protection accorded under this Policy will be revoked if:

a. The Whistleblower participated in the Improper Conduct disclosed;
b. The Whistleblower willfully discloses false or untrue statements;
c. The Whistleblower commits an offence under the Whistleblower Protection Act 2010;
d. The disclosure made is frivolous or malicious; or
e. The disclosure is made with the motive solely or substantially of avoiding dismissal or other disciplinary action.

iii. Any person who makes a disclosure of Improper Conduct to Malaysia Airports, knowing or believing that any material statements in the disclosure is false or untrue commits a criminal offence under the Whistleblower Protection Act 2010.

iv. Malaysia Airports will not tolerate any Detrimental Action against the Whistleblower under the Policy. Anyone who takes Detrimental Action against the Whistleblower will be subjected to disciplinary action which may include termination of employment.

v. If the Whistleblower feels that Detrimental Action has been exercised against him/her, he/she must immediately contact the WIC Secretariat to file his/her apprehension.

5.3 Malaysia Airports Response

All Concerns raised will be evaluated by the CID and where required, investigated. Appropriate corrective action will be taken if warranted by the investigation.

5.4 Untrue Allegations

i. If the Whistleblower raises a concern in good faith, and an investigation into the Concern does not proceed, the Whistleblower shall still be eligible for protection pursuant to this Policy.
ii. If the Whistleblower, who is an Employee or Director of Malaysia Airports, raises a Concern frivolously, maliciously or for personal gain, disciplinary action may be taken against him/her.

5.5 Anonymous Reporting

Generally, Malaysia Airports does not entertain anonymous reporting as any follow up to ascertain the facts or to obtain further information for investigation purposes would be difficult. Nevertheless, Malaysia Airports subscribe to the MS ISO 37001:2016 Anti-Bribery Management Systems which encourages anonymous reporting. Although Malaysia Airports is not expected to address any anonymous reports, the WIC may consider investigating anonymous Concern(s) raised via an anonymous letter or email having considered the following:

i. The seriousness of the nature of the Concern relates to the scopes as prescribed in items 4.4 and 4.5;
ii. The potential credibility of the Concern;
iii. The adequacy of information provided i.e what, when, where, why, who, how; and
iv. The possibility of confirming the Concern from credible sources from available sources such as supporting document(s) enclosed with the Concern.

6.0 DISCLOSURE OF IMPROPER CONDUCT

6.1 Disclosure of Improper Conduct can be made to any of the following reporting channels:

i. Email to wic_secretariat@malaysiaairports.com.my
ii. Online submission via Reporting of Concern Form at Malaysia Airports' corporate website.
iii. By mail in a sealed envelope marked "Strictly Private and Confidential" to:
WIC Secretariat
Corporate Integrity Division
Malaysia Airports Holdings Berhad
Malaysia Airports Corporate Office
Persiaran Korporat KLIA
64000 KLIA, Sepang
Selangor
iv. Meet any WIC Member or the WIC Secretariat in person
v. Call the Whistleblowing General Hotline at 019-6592263

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

6.2 Reports of suspected or instances of Improper Conduct should be made promptly since the earlier it is reported, the easier it will be to take effective action.

6.3. Reports should be objective and relevant, providing as much detail and be as specific as possible. Reports should include the following information:

a. Type or description (what) of Improper Conduct;
b. Date, time (when) and location (where) of incident of the Improper Conduct;
c. The identity (who) of the alleged individual who has committed or is involved in the Improper Conduct;
d. Any other details of the Concern raised e.g. how and why, in relation to the Improper Conduct;
e. Particulars of witnesses of the Improper Conduct, if any;
f. Particulars or production of documents or evidence of the Improper Conduct, if any; and
g. Contact details of the Whistleblower.

6.4 The Whistleblower is encouraged to provide his/her full name and contact details, to facilitate Malaysia Airports to clarify or obtain further information for purposes of further investigation into the Improper Conduct.

6.5 The Whistleblower also has the right to report to relevant government or regulatory authorities and enforcement agencies in Malaysia as prescribed by the Whistleblower Protection Act 2010.