Whistle-blowing Policy

The term ‘whistle-blower’ refers to anyone, typically an insider or staff, who alerts his supervisors or the appropriate authorities to actual or suspected misconduct within an organisation. Whistle-blowers usually act because they have professional or ethical concerns about what is happening in their organisation.

Staff are encouraged to raise genuine concerns about possible wrongful practices in the organisation. Wrongful practices include mismanagement and misuse of resources, or inappropriate conduct and behaviour. Such act or irregularity includes those which may likely to be committed or in the process of committing or had been committed. The following listing provides some examples but is not exhaustive:

1. Fraud
   • Deliberate error in the preparation, evaluation, review, audit of financial accounts and records
   • Theft, forgery or alteration of cheques
   • Stealing of cash/assets
   • Pocketing money from clients/beneficiaries
   • Submitting false invoices
   • Making unsubstantiated claims for overtime and transport allowance
   • Accessing clients/beneficiaries’ personal records for purposed of committing identity theft
   • Unauthorised use/wrongful disclosure of privileged or confidential information.
2. Corruption
   • Bribery
   • Engaging in business transactions with an undisclosed conflict of interest
   • Extortion which involves obtaining a favour or money by intimidation, violence or misuse of influence or authority.
3. Others
   • Failure to observe a legal obligation
   • Miscarriage of justice
   • Endangering the health or safety or persons or the environment
   • Financial and non-financial administrative malpractice g. not observing proper procedures for tendering
   • Academic or professional malpractice g. violating or intellectual property rights or failure of integrity in research
   • Improper conduct or unethical behaviour, including sexual harassment
   • Participation in or condoning a reportable wrongdoing through willful suppression or concealment of any information relating to a wrongdoing.

Any suspected wrongdoing should be reported expeditiously. The earlier the concern is raised, the easier it is for MENDAKI to investigate and take effective Concerns or information should be raised or provided in writing or email: [email protected] to the Chairman of Audit Committee (AC) who will delegate the Chief Executive Officer to handle all whistle-blowing reports in MENDAKI. In the case where reporting to the Chief Executive Officer is a concern, the Chairman of AC will follow up in consultation with the Board of MENDAKI.

Ideally, the whistle-blower should be detailed in setting out the background and history of events and the reasons for the concern. To facilitate investigation of the allegations, the disclosure/ whistle-blowing report should contain as much details as possible, including (but not limited to):

1. Nature of the alleged wrongful practice
2. Names of people allegedly involved
3. Names of any witnesses
4. Dates, times and locations of incidents
5. When the incident was first observed
6. Details of any evidence you may have or know of
7. The value of any money or asset involved
8. Frequency or occurrence
9. Name and contact details of whistle-blower.

MENDAKI strongly encourages the whistle-blower to identify himself/herself when raising the concern or providing information. This is to facilitate appropriate follow-up actions and investigations. All whistle-blowing reports, including the identity of the whistle-blower, will be kept strictly confidential except where:

1. MENDAKI is under a legal obligation to disclose information provided;
2. the information is already in the public domain;
3. the information is given on a strictly confidential basis to legal/auditing or professionals for the purpose of obtaining professional advice/assistance; or
4. the information is given to the Police or other statutory authorities for criminal investigation.

In the event that MENDAKI is faced with circumstances where the whistle- blower’s identity has to be revealed, the management team will discuss this with the whistle blower first.

In order not to jeopardise the investigations into the alleged wrongful practice, the whistle-blower is expected to keep the disclosure and all details pertaining to it strictly confidential.

If the disclosure was made in good faith, the whistle-blower can rest assured that no action will be taken by MENDAKI against him/her nor will his/her designation in MENDAKI be affected, even if subsequent investigations reveal no wrongful

However, any reports that are found to be malicious, frivolous or an abuse of this whistle-blowing policy, will be investigated, and the person who made the report will be subject to disciplinary action or even face legal consequences.

All legitimate concerns raised, or information provided will be reviewed and investigated, if deemed necessary. Upon receipt of a report of wrongful practice, the Chief Executive Officer/ Chairman of Audit Committee in consultation with Chairman of MENDAKI will decide how best to proceed with the matter and whether to initiate an investigation based on the following factors: a. Severity of the issues raised; b. Credibility of the concern or information; and c. Likelihood of confirming the concern or information from attributable sources.

Where necessary, an independent investigation may be initiated by MENDAKI based on the merits of each report, for example:

• External auditor;
• Internal auditor;
• Forensic accountant;
• The Police; or
• Corrupt Practices Investigation Bureau

The amount of contact between the whistle-blower and the investigator will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistle-blower during the course of the investigations.

Based on the investigation report, the Audit Committee, upon consultation with the Board, shall determine the appropriate actions to be taken to address the whistle blowing report Where appropriate, the whistle-blower will be notified of the outcome. All whistle-blowing reports will be maintained by the AC and accessible to MENDAKI Board members only.

MENDAKI will take all reasonable steps to protect the whistle-blower from reprisal or negative personal consequences. If it is determined that a whistle-blower has experienced any reprisal or victimisation, the Audit Committee shall recommend appropriate remedial action to be taken.