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Whistleblowing Policy
Policy Statement
1. Hitachi Sunway Information Systems Sdn Bhd (“Hitachi Sunway”) is committed to the highest standard of integrity, openness and accountability in the conduct of its businesses and operations. It aspires to conduct its affairs in an ethical, responsible and transparent manner. Recognizing the abovementioned values, Hitachi Sunway provides avenue for all employees and external parties/members of public to disclose any improper conduct within Hitachi Sunway.
 
Objective of the Policy
2. This policy is to provide an avenue for all external parties/public to disclose any improper conduct in accordance with the procedures as provided for under this policy and to provide protection for external parties/members of public who report such allegations.
 
Scope of the Policy
3. This policy is designed to facilitate external parties, members of the public, customers and any other stakeholders/persons providing services to Hitachi Sunway Group, including consultants, vendors, independent contractors, external agencies and/or any other party with a business relationship with Hitachi Sunway disclose any improper conduct through internal channel. Such misconduct or criminal offences include the following:-
a) Fraud;
b) Bribery & Corruption;
c) Abuse of Power;
d) Conflict of Interest;
e) Theft or embezzlement;
f) Misuse of Hitachi Sunway’s Property;
The above list is not exhaustive and includes any act or omissions, which if proven, will constitute an act of misconduct or any criminal offence under relevant legislations in force.
 
Procedure in Making a Disclosure
4. All disclosures are to be channelled in accordance with the following manner:-.
a) By post to Hitachi Sunway Information Systems Sdn Bhd at Level 11, The Pinnacle, Persiaran Lagoon Bandar Sunway, 47500 Selangor, Malaysia
Attention: Chief Compliance Officer; or 
 
5. To facilitate an investigation into the alleged wrongdoing, where possible and applicable, the following information should be included when making a disclosure: -
a) Brief description of the misconduct;
b) The date and location of the incidence;
c) The identity of the wrongdoer;
d) Particulars of witnesses, if any;
e) Supporting evidence and/or documents;
f) Other details deemed to be useful to facilitate screening and action to be carried out.
 
Protection to Whistleblower
6. A whistleblower will be accorded with protection of confidentiality of identity, to the extent reasonably practicable. Such protection is accorded even if the investigation later reveals that the whistle-blower is mistaken as to the facts and the rules and procedures involved.
 
Anonymous Whistleblower
7. Any external party or member of the public who wishes to report improper conduct is required to disclose his identity to Hitachi Sunway in order for Hitachi Sunway to accord the necessary protection to him. However, Hitachi Sunway reserves its right to investigate into any anonymous disclosure.
 
Notification
8. Upon the completion of the whistleblowing process and procedures, the whistle-blower will be accorded the privilege to be notified on the outcome of the disclosure.
 
Hitachi Sunway reserves the right to amend this policy from time to time.

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