I. Purpose

This whistleblowing policy is designed to encourage employees of Widetech (Malaysia) Berhad ("the Company" or "Widetech" together with its subsidiaries, the "Group"), and related third parties (e.g. customers, suppliers, etc., who deal with the Company) ("Third Parties") to raise concerns, in confidence, about misconduct, malpractice or irregularities in any matters related to the Company.

This Policy is designed to:

a) Promote and maintain high transparency and accountability in the workplace;
b) Promote good corporate governance practices in the work place;
c) Ensure that stakeholders can raise concerns without fear of reprisals and safeguard such person's confidentiality;
d) Protect the whistleblower from reprisal as consequence of making a disclosure;
e) Provide a transparent and confidential process for dealing with concerns;
f) Protect the long term reputation of PCB;
g) Support PCB's values; and
h) Maintain a healthy working culture and efficient company.

II. Responsibility to Report

The Code of Ethics of Widetech ("COE") provides the guiding principles for all Board members and employees to take the right action, behave with integrity and honesty, treat people fairly, respect diversity, obey all laws, accept accountability, communicate openly, and always behave in a way that is beyond reproach.

Under the COE, employees are required to promptly alert their supervisor or higher management of business and work-related situations that could be damaging to Widetech or cause harm to others such as emergencies, crimes, accidents, irregularities or other unexpected events; and to take reasonable action to prevent damage or harm. Employees could be in breach of the COE if they assist or authorize others in activities that breach the COE, conceal or fail to report any known or suspected breaches by others. Employees and Third Parties may also have a duty to report corruption to the authorities if required to do so by local regulations.

III. Protection

Persons making genuine and appropriate complaints under this policy are assured of fair treatment. In addition, Widetech Group's employees are also assured of protection against unfair dismissal, victimization or unwarranted disciplinary action, even if the concerns raised turned out to be unsubstantiated. Widetech Group reserves the right to take appropriate actions against anyone (employees or Third Parties) who initiates or threatens to initiate retaliation against those who have raised concerns under this policy. In particular, employees who initiate or threaten retaliation will be subject to disciplinary actions under the COE, which may include dismissal. Management will support all employees and encourage them to raise concerns without fear of reprisals.

IV. Confidentiality

Widetech Group will make every effort, within its capacity to do so, to keep a Whistleblower's identity confidential. Widetech Group will endeavor to advise a Whistleblower in advance if his or her identity may become apparent or need to be disclosed. Should an investigation lead to a criminal prosecution, it may become necessary for a Whistleblower to provide evidence or be interviewed by the relevant authorities.

V. Types of Misconduct, Malpractice and Irregularity

It is not possible to give an exhaustive list of the activities that constitute misconduct, malpractice or irregularity covered by this policy. For example, Widetech Group expects all employees to observe and apply the COE principles in the conduct of Widetech Group's business. Employee behavior that is not in line with COE principles could constitute a misconduct, malpractice, or irregularity that should be reported. The principles of COE relate to :

  • - integrity and honesty
  • - confidentiality
  • - avoiding conflicts of interest
  • - responsibilities
  • - safety, health and environment
  • - compliance with financial controls and reporting requirements
  • - moderation in gifts
  • - compliance with laws and regulations
  • - protecting our information, records and assets
  • - compliance with the code and obligation to report

Reporting and Investigations

a) Reporting Channels
For employees, they may prefer to have an initial discussion with his/her manager or Human Resources Manager ("HRM"). However, the HRM must in turn report any potential or actual misconducts, malpractices or irregularities to the Executive Chairman ("EC"). If the employee feels uncomfortable doing this (e.g., his/her line manager has declined to handle his/her case or it is the line manager who is the subject of the report), then the employee can contact EC directly. Business partners, suppliers and Third Parties are encouraged to report directly to EC.

However, if it involves sensitive issue that may not convenient to convey to EC, then employee or Third Party can contact any one of the Independent Non-Executive Directors.

b) Reports and Supporting Documentation
While Widetech Group does not expect the Whistleblower to have absolute proof or evidence of the misconducts, malpractices or irregularities reported. The report should show the reasons for the concerns and full disclosure of any relevant details and supporting documentation. If he/she makes a report in good faith then, even if it is not confirmed by any subsequent investigation, the Whistleblower's concerns would be valued and appreciated.

All complaints will be treated strictly private and confidential.

c) Investigations
Every report or complaint received will be assessed.

If there is sufficient evidence to suggest that a case of possible criminal offence or corruption exists, the matter will be reported and addressed to the relevant authority accordingly.

A full report on the investigations conducted without revealing the identity of the Whistleblower. For confirmed cases of COE violations, the normal process is for the HRM to determine what disciplinary action is appropriate and make a recommendation to the EC for final decision.

VII. False Reports

If a Whistleblower makes a false report maliciously, with an ulterior motive, or for personal gain, Widetech Group reserves the right to take appropriate actions.

VIII. Anonymous Reports

As Widetech Group takes reporting of misconducts, malpractices, and irregularities seriously and wants to conduct warranted investigations of both potential and actual violations, it is preferred that these reports are not made anonymously. However, it is recognized that for any number of reasons, employees or Third Parties may not feel comfortable reporting potential violations directly to EC. In these cases, anonymous reports may be submitted to any one of the Independent Non-Executive Directors.

IX. Responsibility for Implementation and Review of Policy

This policy has been approved and adopted by the Board of the Company. The Audit Committee has been delegated overall responsibility for implementation, monitoring and periodic review of this policy and any matter raised must be put forward to the Board for approval.

IX. Disclosure Procedure

1. All complaints/disclosures should be addressed/ reported to :-

Name : DATUK DR. NG BEE KEN

Email : kennybkn@yahoo.co.uk

Mailing Address : Widetech (Malaysia) Berhad K-09-01, No. 2, Jalan Solaris, Solaris Mont' Kiara 50480 Kuala Lumpur, Malaysia.

2. If any individual believes reasonably and in good faith that improper conduct or malpractices exists in the Widetech, the individual may make a disclosure of improper conduct and immediately report the information to the above contact person. Information should be reported as soon as the individual becomes aware of the facts that are the basis of the potential irregularity or complaint. An individual reporting such information should be prepared to provide as much information as possible to ensure that the matter can properly be investigated.

3. If any individual believes reasonably and in good faith that improper conduct or malpractices exists in Widetech, the individual may make a disclosure of improper conduct and immediately report the information to the above contact person. Information should be reported as soon as the individual becomes aware of the facts that are the basis of the potential irregularity or complaint. An individual reporting such information should be prepared to provide as much information as possible to ensure that the matter can properly to be investigated.

3.4. The WBC member receiving the report will then immediately convene a meeting of the WBC. If the WBC determines that the information is credible and the complaint has to be further investigated, the WBC will inform the Managing Director ("MD") and advise MD to proceed with the investigation in accordance with the procedures laid in this Policy.

3.5. No person entitled to protection shall be subjected to retaliation, intimidation, harassment, or other adverse action for reporting information in accordance with this Policy. Any person entitled to protection who believes that he or she is the subject of any form of retaliation for such participation should immediately report the same as a violation of and in accordance with this Policy.

3.6. Any individual within PCB who retaliates against another individual who has reported a violation in good faith or who, in good faith, has cooperated in the investigation of a violation is subject to discipline, including termination of employment or contract for services.

3.7. As provided by law, an individual may also report illegal or unethical practices directly to statutory bodies such as the Malaysian Anti-Corruption Commission, the Securities Commission, Bursa Malaysia, the Royal Malaysian Police or other similar government agencies in other countries. In such an event, protection of the whistleblower is also provided under the respective laws such as the Whistleblower Protection Act 2010.