Unethical Wrongdoings

1. The following unethical wrongdoings committed by any staff in the conduct of business shall be reported:

1. 1. 1. Fraud;
      2. Corruption, bribery or blackmail;
      3. Breach of legal or regulatory obligations and common code of ethics;
      4. Conflict of interest;
      5. Sexual harassment;
      6. Misuse of confidential information and property of the Group;
      7. Criminal offences; and
      8. Concealment of any or a combination of the above.

Principles

2. The general principles governing this whistle blowing policy are as follows:

• 1. 1. All reports or complaints would be treated with strictest confidence;
     2. The identity of the whistle-blower(s) will remain anonymous during the investigation;
     3. The whistle-blower(s) will be informed of the investigators handling the matter and its status;
     4. Whistle-blower(s) are protected against any detrimental action in reprisal for whistle blowing unethical conducts. However, this protection would not be extended to someone who maliciously raises matter he/she knows is untrue; and
     5. The Board reserves its right to amend this policy as and when needed.

Whistleblowing Channel

3. Whistle-blower(s) who believe reasonably and in good faith that violation or malpractice of unethical wrongdoings exist should report the wrong doing to the Board Chairman or the Audit and Risk Management Committee Chairman by emailing to wb@k-one.com or post to 66 & 68, Jalan SS 22/21, Damansara Jaya, 47400 Petaling Jaya, Selangor, Malaysia.

4. Whistle-blower(s) are required to identify himself or herself in order for the Board Chairman to accord the necessary protection to him or her. However, the Board reserves its right not to investigate any allegation communicated by anonymous whistle-blower(s).

Action

5. All alleged unethical wrongdoings will be investigated, except those from anonymous whistle-blower(s), wherein, the Board reserves the right not to investigate. The Internal Auditors shall review each claim and pursue it to the extent that the information and evidence received allows. The Internal Auditors shall begin preliminary investigations to establish whether the claim has merit and can be substantiated and reported to the Chairman of the Audit and Risk Management Committee for further action.

6. The Board Chairman or the Audit and Risk Management Committee Chairman may seek assistance from other resources within and outside the Group when conducting its investigation at the cost of the Group.

7. Upon completion of investigation, the Board Chairman or the Audit and Risk Management Committee Chairman shall decide the appropriate actions for:

1. 1. 1. Informing the whistle-blower(s) the status of the findings;
      2. Initiating disciplinary action against any persons who has committed unethical conducts;
      3. Making a police report where the unethical conduct constitutes a criminal offence; and
      4. Recommending steps to be implemented to prevent a similar situation from repeating in the future