1.0 PURPOSE

The purpose of this policy is to establish a transparent and accountable communication channel for employees and stakeholders to voice their concerns in an effective, responsible, and secured manner when they become aware of actual or potential wrongdoings.

This policy shall address Iegal obligations, miscarriage of justice, bribery & corruption, health issue or safety & environment related issues.

2.0 SCOPE

This policy applies to all shareholders, board of directors, chief executives, top management including all managers, all employees, contractors, consultants, temporaries, interns, and other workers including all personnel that are affiliated with Strateq.

3.0 DEFINITION

3.1 What is Whistleblowing and Who is Whistleblower?

Whistleblowing is the act of disclosing a wrong doing or improper conduct within an organization to others.

Whistleblower means any person who makes a disclosure of improper conduct, alleged dishonest or illegal activity occurring in an organization. Whistleblowers can be employees, former employees, suppliers, contractors, clients, or any individual who becomes aware of improper business activities occurring in an organization.

3.2 Types of Whistleblowing

Internal whistleblowing is when an employee discovers corporate misconduct and brings it to the attention of the relevant party in the organization, who will then follow established procedures to address the misconduct within the organization.

External whistleblowing is when an employee discovers corporate misconduct and brings it to the attention to Iaw enforcement agencies or media to initiate an investigation. Some examples of law enforcement include Police, Malaysian Anti-Corruption Commission (MACC), Customs Department, Road Transport Department (JPJ), Immigration Department, Iawyers, news media.

4.0 DISCLOSURE OF IMPROPER CONDUCT

Strateq encourages openness and is committed to ensure that employee can speak up with confidence if they have genuine concerns about improper conduct, some examples are below:

1. Incidents of fraud, corruption or bribery;
2. Abuse of Power;
3. Breach of Law, Criminal offences;
4. Misuse of Company’s Property;
5. Non-Compliance with STRATEQ Policies, practices, procedures or other rules of conducts;
6. Improprieties in matters of financial reporting;
7. Situation which poses a danger to health, safety or any individual or significant danger to the environment;
8. Detrimental action taken against whistle-blower (including person closely associated).

5.0 PROTECTION TO WHISTLEBLOWER

a) STRATEQ is committed to provide the following protections to a Whistleblower for making a genuine disclosure.

1. Confidentiality of identity;
2. Immunity from civil and criminal action;
3. Protection against detrimental action (e.g. demotion, suspension or termination of employment or service);
4. The identity and personal information of the Whistle-blower and the alleged wrongdoer may be revealed to persons involved in the investigations or any other process.

b) Protection under 6(a) above will be accorded by the Company only when the Whistle-blower satisfies all the following conditions:

1. The disclosure is done in good faith;
2. The Whistle-blower is aware that the information and any allegations disclosed are true;
3. The Whistle-blower has not communicated the disclosure to any other party not related to the disclosure; and
4. The disclosure made is not for personal gain or interest.

c) Employee and industrial relations related issues and human resources related issues are excluded from the operation of this Policy because they are other established mechanisms to raise such complaints.

6.0 HOW TO WHISTLEBLOW

a) All complaints/disclosures will be channelled to Whistleblowing Committee for further action through Whistleblower Report Form available.

b) The Committee shall comprise of the following:

1. Chairman of the Board
2. Group Managing Director
3. Human Resource Director
4. Chief Financial Officer
5. Company Secretary
6. Compliance Director

c) The Committee shall have the authority to:

1. Determine the legitimacy of the disclosure;
2. Direct further action; and
3. Determine who should conduct the investigation (i.e. Head of Department or Senior Management or engage external expertise)

d) The Whistle-blower can confidentially raise issues of concern about improper conduct that he/she is aware of through his/her work/dealing using the attached Whistleblowing form to strateq_whistleblower@strateqgroup.com or mail the same form to the following address:

Strateq Sdn. Bhd.

No. 12, Jalan Bersatu 13/4

46200 Petaling Jaya

Selangor Darul Ehsan

Attention: Group Managing Director

7.0 REQUIRED EVIDENCE

a) The Whistle-blower should be able to provide the disclosure in writing, information regarding the type of activity or conduct, identity of the person(s) suspected as being involved, when it occurred and who was affected.

b) The Whistle-blower must have first-hand knowledge or information of the facts, i.e. information obtained from third party or ‘hearsay’ will not be entertained. However, the Whistle-blower should not be discouraged from making a report because they are unsure whether there is sufficient evidence to support their allegations.

8.0 REFERENCE

a) Anti-Bribery and Corruption Policy

9.0 REVIEW OF THIS POLICY

STRATEQ Board can modify this Policy unilaterally at any time without notice.

Modification may be necessary, among other reasons, to maintain compliance with Iaws and regulation and/or accommodate organizational changes within the Company or Group. However, the modification made shall be effective after the same is circulated to employees in writing or electronically.

This Policy was approved by the Board of Directors of Strateq Sdn. Bhd. and its Group of Companies on 18 August 2020.

10.0 WHISTLEBLOWER PROTECTION ACT 2010

In the event there are discrepancies between this Policy and the Whistleblower Protection Act 2010 (“Act”), the Act shall prevail.