Whistleblowing Policy

1. INTRODUCTION
   The objective of this Policy is to provide a structured reporting channel and guidance to the Employees and external parties to raise their concerns about any possible improprieties within the Group.
   The Policy aims to:
   1. encourage the Employees and external parties to feel confident in raising, questioning and acting upon genuine concerns about improprieties.
   2. provide avenues for the Employees and external parties to raise concerns about improprieties and receive feedback on any action taken.
   3. reassure the Employees and external parties that they will be protected from possible reprisals or victimisation for whistleblowing in good faith.
       
2. SCOPE
   2.1 The scope of this Policy covers possible improprieties listed below:
   1. Commission of fraud, bribery and/or corruption
   2. Unauthorised use of Group’s money, properties and/or facilities
   3. Exposure of Group’s properties, facilities and/or staff to the risks of safety and security
   4. Abuse of position
   5. Involvement in unlawful act
   6. Negligence/malpractice
   7. Disclosure of Group’s information without proper authorisation
   
   2.2 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 and Conduct or any criminal offence under relevant legislations in force.
   
   2.3 The Policy however, does not cover:
   1. False concerns
   2. Defaming concerns
   3. Concerns with no basis or insufficient evidence
   4. Malicious concerns
       
3. POLICY
   3.1 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.
   
   3.2 Protection Accorded to Whistleblower
   1. Protection against any detrimental action within the Group to the extent reasonably practicable will be accorded only when the Whistleblower satisfies all the following conditions:
      • the reporting was done in good faith; and
      • Whistleblower has reasonable grounds when raising a concern; and
      • Whistleblower only communicated the concern to any WIC member or the WIC Secretariat.
   2. However, protection accorded under this Policy will be revoked if:
      • the Whistleblower participated in the improper conduct disclosed;or
      • the Whistleblower wilfully discloses false statements; or
      • the disclosure made is frivolous or malicious; or
      • the disclosure is made with the motive of avoiding dismissal or other disciplinary action.
   3. MAHB will not tolerate any detrimental action against the Whistleblower. Anyone who takes detrimental action against the Whistleblower will be subjected to disciplinary action which may include termination of his/her employment.
   4. If the Whistleblower feels that detrimental action has been exercised against him/her, he/she must immediately contact any WIC member or the WIC Secretariat to file his/her apprehension.
   
   3.3 MAHB Response
   1. All concerns raised will be given due consideration by WIC and if the need arises, thoroughly investigated. 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.
   
   3.4 Untrue Allegations
   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.
   
   3.5 Anonymous Reporting
   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 it meets any of the following conditions:
   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.
       
4. DISCLOSURE OF IMPROPER CONDUCT
   4.1 Disclosure of improper conduct can be made to any of the following reporting channels:
   1. Email to wic_secretariat@malaysiaairports.com.my
   2. Online submission via Reporting of Concern Form at Malaysia Airports corporate website
   3. 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

   4. Meet any of the WIC member or the WIC Secretariat in person
   5. Call the Whistleblowing 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 about the issues raised.
   
   4.2 Reports of suspected or instances of improper conduct should be made promptly for effective action.
   
   4.3 Reports should be objective, specific and detailed. Reports should include the following information:
   • Nature of improprieties;
   • Date, time and location of incident;
   • The identity of the alleged wrongdoer;
   • Particulars of witnesses, if any;
   • Particulars or production of documentary evidence, if any; and
   • Contact details of the Whistleblower

(Effective 30 November 2020)