ABOUT

Corporate Governance

Anti-Bribery And Corruption Policy

1. Introduction

  1. This Anti-Bribery and Corruption Policy is issued to provide Jetson Group’s Employees, and any Third Parties that are currently engaged or to be engaged by Jetson Group with basic guidelines on how to deal with improper solicitation, bribery and other corrupt activities and issues that may arise in the course of business.
    Kumpulan Jetson Berhad and all its subsidiaries and associate companies are collectively referred to as “the Jetson Group” or “the Group”.
  2. This Anti-Bribery and Corruption Policy was prepared in line with the requirement set forth in the Guidelines on Adequate Procedures issued on 10 December 2018 by the Prime Minister’s Office pursuant to Section 17A (5) of the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act 2009”). However, this is not a definitive answer and in cases where there is a conflict between mandatory laws and the principles contained in this Anti-Bribery and Corruption Policy, the law shall prevail.
  3. This Anti-Bribery and Corruption Policy applies in addition to, and not to the exclusion of, Jetson Group’s other policies and procedures including its Code of Ethics & Conduct and Whistleblower Policy.
  4. This Anti-Bribery and Corruption Policy has been approved by the Board at its meeting held on 29 April 2020 and will be effective from 1 June 2020.
  5. All recipients of this Anti-Bribery and Corruption Policy are expected to read and to adhere to this Anti-Bribery and Corruption Policy. If there is any query on the Anti-Bribery and Corruption Policy, please consult Group Human Resource & Administration Department.

2. Purpose

  1. The purpose of this Anti-Bribery and Corruption Policy is to:
    1. set out Jetson Group’s responsibility, and those working for it, to comply with laws against bribery and corruption;
    2. provides information and guidance to those working for Jetson Group on how to recognize and deal with corruption and bribery issues

3. Applicability

  1. The compliance of this Anti-Bribery and Corruption Policy is mandatory and is applicable to:
    1. All business entities over which Jetson Group has effectively control;
    2. All individuals working for Jetson Group wherever located, at all levels and grades including directors, senior management and employees (whether full time, probationary, contract or temporary) (collectively “Employees”); and
    3. All Third Parties that are currently engaged by Jetson Group or to be engaged by Jetson Group in the future (collectively “Associated Third Parties”)
      All Third Parties that are currently engaged by Jetson Group or to be engaged by Jetson Group in the future (collectively “Associated Third Parties”)
  2. Joint-venture companies in which Jetson Group does or does not has effective control interest and associated companies are encouraged to adopt these or similar principles;

4. Definitions

Bribery Offering, giving, receiving or soliciting something of value in an attempt to illicitly influence the decisions or actions of a person a position of trust within an organization
Conflict of Interest When the Employee is or may be in a position to take advantage of his/her role by using confidential information, assets and other resources for his/ her personal gain or for the advantage of his Closely Related Person.

A “Closely Related Person” is someone you are related to, have a personal friendship with, or anyone living in the same household as you.

Corruption The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government.
Donation A Donation is a charitable gift of money, goods or services given to a group or organization without the anticipation of benefit in return.
Facilitation Payment A “Facilitation Payment” includes any payment or advantage made to an individual in control of a process or decision in order to secure or expedite a routine or administrative duty or function. It is illegal under the MACC Act 2009 as it falls within the meaning of gratification of bribery.
Gifts A gift comprises of cash money, free airfares, shares, travelling facilities, club membership, any form of commission, jewelry, and any item of high value.
Hospitality The friendly reception and entertainment of guests. Hospitality may range from exorbitant restaurant meals to sponsored travel and accommodation.
Kickbacks Payment of any portion of a contract made to employees of another contracting party or the utilization of other techniques, such as subcontracts, purchase orders or consulting agreements to channel payment to Public Officials, political parties, party officials or political candidates, to employees of another contracting party, or their relatives or business associates.
Sponsorship Sponsorship is a contribution in money, in kind, or in services to support an event, activity, person or organization in return for certain and specified benefits or value for Jetson Group’s business activities.

5. In Principles

  1. Jetson Group take a zero-tolerance approach against all forms of bribery and corruption, whether direct or indirect, and no Employees or Associated Third Parties should commit, be a party to or be involved in any bribery or corruption.
  2. Jetson Group is committed to adhering to best and acceptable practice in corporate governance and observing the highest standards of integrity and behavior in all its relationship and business dealing wherever it operates and to implement and enforce effective system to counter bribery.
  3. Jetson Group will uphold all relevant anti-bribery and corruption laws, which include compliance with the Malaysian Anti-Corruption Commission Act 2009 (Act 694) and the Malaysian Anti-Corruption Commission (Amendment) Act 2018 and any of its amendments or re-enactments that may be made by the relevant authority from time to time.
  4. Jetson Group will undertake a bribery and corruption risk assessment across our business when appropriate and ensure that it has adequate procedures in place to address those risks.

6. Responsibilities

  1. The Board of Directors is collectively responsible to provide oversight of this Anti-Bribery and Corruption Policy and the Chief Executive Officer and the Management are responsible for ensuring the compliance with this policy.
  2. All Employees, and any Associated Third Parties have a duty to read, understand and comply with this Anti-Bribery and Corruption Policy. All Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy, and reporting of bribery and other forms of violation as early as possible via the channel outlined in Jetson Group’s Whistleblowing Policy.
  3. Bribery and corruption are criminal offences and carry very serious sanctions. An Employee will be personally liable whether he or she pays a bribe himself or herself or whether he or she authorizes, assists or conspires with someone else to violate the anti-corruption or anti-bribery law. Punishment for violating the law are against him/her as an individual and may include imprisonment, probation, mandated community service and monetary fines and others which will not be paid by Jetson Group.
  4. Besides, Employees and Third Parties working for Jetson Group should also aware that violation of any of the Policy’s provisions may result in disciplinary action, including dismissal or termination of contract. Jetson reserves its right to terminate its contractual relationship with those who breach this Policy.

7. No Bribes Policy

  1. Jetson Group strictly prohibits bribery and corruption in any form, whether direct or indirect. No Employees and Business Associates should commit, be a party to or be involved in:
    1. Give, Promise to Give, or Offer a Bribe; All Employees and Associated Third Parties shall not directly, or indirectly through third party, give, offer or promise any financial or other advantage to recipient (public official/ private party or their family member) to improperly obtain or retain business or to obtain any other business advantages.
    2. Request, Agree to Receive or Accept a Bribe All Employees and Associated Third Parties shall not directly, or indirectly through third party, request, agree to receive or accept a financial or other advantage intending to induce or reward a breach of trust, impartiality or good faith.
  2. No Employee or Associated Third Parties will suffer demotion, penalty or other adverse consequences in retaliation for refusing to pay or receive bribes or participate in other illicit behavior.

8. Conflict of Interest

  1. A Conflict of Interest does not necessarily involve improper or corrupt behavior. Nevertheless, it may give rise to risk of bribery i.e. being exposed to solicitation or extortion as result of failing to inform management about a Conflict of Interest or acting improperly in favor of another interest.
  2. As such, all Employees are required to make a declaration and withdraw from taking any action or participating in any decision-making process in matters where they have or potentially have a conflict of interest.
  3. Associated Third Parties are required to declare their interest prior to participating, onboarding or when there is a change of circumstances.
  4. Jetson Group reserves the right to discontinue involvement of any of the Employees or Associated Third Parties in such dealing if they perceive any conflict of interest.

9. Facilitation Payment and Kickbacks

  1. Jetson Group strictly prohibit any receiving, giving and promising of Facilitation Payments unless there is an imminent threat or danger to an employee, in such circumstances, a payment may be made but it must be immediately reported to Group Human Resource and Administration Department.
  2. Likewise, all Employees and Associated Third Parties must avoid any activity that might lead to, or suggest that a Kickback will be made or accepted by Jetson Group.

10. Gifts and Hospitality

  1. Jetson Group does not prohibit normal and appropriate hospitality to or from third parties. However, any gifts and hospitality given or received must be in compliance with law and must not violate this Anti-Bribery and Corruption Policy and Code of Ethics & Conduct. All forms, manifestations and appearances of bribery are opposed.
  2. Employees are permitted to offer, give and receive reasonable and customary gifts and hospitality, but only if all the following conditions are:
    1. It is not done with the intention to obtain an improper benefit;
    2. It is appropriate professional nature and be both reasonable and appropriate in terms of value and frequency;
    3. It is not cash (or cash-equivalents such as gift vouchers or gift cards), except for giving / receiving of very nominal value amount (RM10.00 or less) in accordance with local custom such as ang pow at Chinese New Year;
    4. All requisite approvals are obtained.
  3. All gifts given to Employees and Associated Third Parties must be recorded in Gift Register maintained by Group Human Resources & Administration Department; and all aforesaid gifts must be sent to Group Human Resource & Administration Department while waiting for the management’s decision of the gift treatment.
  4. For further details, please refer to the Section 3.8 of Jetson’s Code of Ethics and Conduct. In the event of inconsistency, this Policy shall prevail.

11. Donations and Sponsorship

  1. All Donations and Sponsorship provided by the Jetson Group must be compatible with Jetson Group’s business activities, reflect Jetson Group’s commitment to operating in an ethical manner and must not to be used as a subterfuge for bribery or illegal payments.
  2. No donation or offer of sponsorship shall be made or offered without the prior approval of the duly authorized executive of the Jetson Group.
  3. Political Contributions
    Contribution to political parties whether directly or indirectly, is strictly prohibited.
  4. Jetson Group does recognize the rights of Employees or Associated Third Parties to use their own funds to make political donations and/or participate in political activities, provided that those activities are not linked in any way to the role that they carry out for the Group. Jetson Group will not make any reimbursement for the Political Contributions made by Employees or the Associated Third Parties.
  5. Charitable Donations and Sponsorships
    Charitable Donations or Sponsorships by Jetson Group may only be made where:

    1. it is made in compliance with applicable laws;
    2. it is not made to secure an improper benefit;
    3. it is made to registered charities with a valid charitable purpose; and
    4. all requisite approval is obtained
  6. All requests for donations or sponsorship must accompanied by written evidence of the proposed donations or sponsorships and to be carried out directly with the end entity/ beneficiary, without any intermediaries.
  7. Risk based due diligence to be conducted, as appropriate, on the recipients of any charitable contributions or sponsorships. This is necessary to prevent contributing to charitable organizations which may be engaged in money laundering or other criminal activities.

12. Business Relationships

  1. Jetson Group expects all Associated Third Parties to review this Anti-Bribery and Corruption Policy and to implement and share the Group’s values and ethical standards. Where necessary, they shall be subjected to due diligence process from time to time to assess their integrity and ability to comply with the Anti-Bribery and Corruption Policy.
  2. Jetson Group reserves the right to terminate any pending negotiations, tender, purchase order or contract that does not comply with the provisions set forth in this Anti-Bribery and Corruption Policy. Jetson Group will not be accountable or liable for any losses, claims or crime, actions arising or due to such terminated transaction.

13. Internal Controls and Record Keeping

  1. Jetson Group is committed to establish and maintain an effective internal control system to counter bribery and corruption. These internal controls comprise financial and organizational checks and balances over Jetson Group’s accounting and record keeping practice and other business processes related to its Anti-Bribery and Corruption Policy and procedures. The system will be regularly reviewed and audited to ensure that it remains effective. 13.2 Jetson Group shall at all times maintain accurate books and records that properly and fairly reflect all financial transactions. No “off-the-book” accounts shall be kept to facilitate or conceal improper payments. 13.3 Jetson Group must keep financial records for a minimum period of 7 years and shall make available all the relevant records for inspection and shall cooperate appropriately with relevant auditors or authorities in all bribery and corruption investigations.

14. Confidentiality and Protection

  1. Jetson Group is committed to ensuring that all disclosures are protected with confidentiality and no one shall suffer any detrimental treatment as result of reporting concerns under this Anti-Bribery and Corruption Policy.

15. Training and Communication

  1. This Anti-Bribery and Corruption Policy would be circulated to all Employees and Associated Third Parties acting on behalf on annual basis and as and when the amendment is made.
  2. Each new Employee/ new Associated Third Parties of Jetson Group should, during their induction program/ upon the engagement, be required to read and signed the policy.
  3. Jetson Group’s zero-tolerance to bribery must be communicated to all suppliers, contractors and business partners at the outset of Jetson Group’s business relationship with them and as appropriate thereafter
  4. To ensure thorough understanding of the Anti-Bribery and Corruption Policy, training and awareness sessions on this Policy will be provided as required and to the level appropriate to respective party.

16. Monitoring and Review

  1. Jetson Group will monitor the effectiveness and review the implementation of this Anti-Bribery and Corruption Policy regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made soonest possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

17. Review of The Anti-Bribery and Corruption Policy

  1. The Board will monitor compliance with the Policy and review the Anti-Bribery and Corruption Policy regularly to ensure that it continues to remain relevant and appropriate.

18. Related Policies and Procedures

  1. This Anti-Bribery and Corruption Policy should be read in conjunction with Jetson Group’s other policy documents including the following:
    1. Code of Ethics & Conduct
    2. Whistleblowing Policy

Background

The Directors, the Management and the employees of Kumpulan Jetson Berhad (the “Company” or “Jetson”), together with that of its subsidiaries (“Jetson Group” or the “Group”) are committed to adhering to the best practice in corporate governance and observing the highest standards of integrity and behaviour in all activities conducted by the Jetson Group, including the interaction with its customers, suppliers, shareholders, business partners and stakeholders, and within the community and environment in which the Jetson Group operates.

It is required that employees display the highest levels of professionalism in all aspects of their work and comply with this Code of Ethics & Conduct (“Code”) and all applicable laws, regulations and other policies applicable within the Jetson Group.

1. Introduction

The Directors, Senior Management and Employees of Kumpulan Jetson Berhad (the “Company” or “Jetson”), together with that of its subsidiaries (“Jetson Group” or the “Group”) are committed to adhering to the best and acceptable practice in corporate governance and observing the highest standards of integrity and behaviour in all activities conducted by the Jetson Group, including the interaction with its customers, suppliers, shareholders, business partners and stakeholders, and within the community and environment in which the Jetson Group operates.

The Directors, Senior Management and Employees of the Jetson Group play an important role in establishing, maintaining and enhancing the reputation, image and brand of the Jetson Group and ensuring the observance to and compliance with the standards of integrity and behaviour that the Jetson Group is committed to.

It is required that the Directors, Senior Management and Employees display the highest levels of professionalism in all aspects of their work and comply with this Code of Ethics & Conduct (“Code”) and all applicable laws, regulations and other policies applicable within the Jetson Group.

It is the Group’s policy that all businesses of the Company be conducted in accordance with the highest ethical standards. Good ethics is good business from both moral and practical perspectives. Each employee must ensure that this policy is communicated to not only his fellow employees, especially new employees, but also all third parties dealing with the Company.

2. Applicability

The Code applies to all Directors, Senior Management and Employees (including full time, probationary, contract and temporary staff) of the Jetson Group (“Employees”).

The standards set out in the Code extend beyond normal working hours and apply to all Employees fulfilling their roles while on the business of the Jetson Group, including afterhours functions, conferences and social activities.

Each Employee has a duty to read and understand the Code. They must also act in compliance with the Code and all applicable laws, regulations and other policies of the Jetson Group. Violation of any of the Code’s provisions can result in disciplinary action, including termination of employment and/or appointment.
 

3. Code Of Ethics & Conduct

  1. 3.1

    Compliance to the Laws, Rules and Regulations

    The Employees must comply with all applicable laws, rules and regulations of the governments, exchanges, commissions in the jurisdictions within the Group operates. Directors and Employees are expected to understand and comply with the laws, rules and regulations that are applicable to their positions and/or work. The Group reserves the right to report any actions or activities suspected of being criminal in nature to the police or other relevant authorities.

  2. 3.2

    Conflict of Interest

    The Employees should avoid involving themselves in situations where there is real or apparent conflict of interest between them as individuals and the interest of the Group. Conflict of interest can arise where the Employee hold any office or possesses any property whereby, whether directly or indirectly, duties or interests are created in conflict with his duties or interests as the Employee. This includes a situation where the Employee, whether directly or indirectly, is interested in a contract or proposed contract with the Company.

    Any Employee found to be in a position of conflict must declare his interest and abstain from taking part in any decision-making process concerning that contract or involving the supplier, customer, agent or competitor as the case may be. Any Employee found to have gained a financial benefit from such contract in which he has failed to declare his interests shall be deemed to have committed a major misconduct and shall be subject to disciplinary action.

    Any situation that creates, or even appear to create a conflict of interest between personal interests and the interests of the Group must be appropriately managed. The conflicts of interest whether actual or potential conflicts must be reported to Human Resources.

  3. 3.3

    Insider Information and Securities Trading

    It is important that insider information (such as the Company’s financial results, knowledge of a proposed major acquisition or disposition or any event that could affect the share price of Jetson) be not disclosed to anyone until it has been officially released to the public. This is to ensure that all investors have access to significant information about the Company at the same time. The Employees must not disclose this insider information to anyone else, whether inside or outside of the Company. The Employees are prohibited to trade in securities or to provide insider information to others to trade in securities of the Company until such information is publicly released.

  4. 3.4

    Confidential Information

    It is pertinent that all Employees exercise caution and due care to safeguard any information of a confidential and sensitive nature relating to the Group which is acquired in the course of their employment, and are strictly prohibited to disclose to any person, unless the disclosure is duly authorized or legally mandated. In the event that an Employee knows of material information affecting the Group, which has not yet been publicly released, the material information must be held in the strictest confidence by the Employee involved until it is publicly released.

  5. 3.5

    Assets and Funds Protection

    The Employees must protect the assets and funds of the Group for legitimate business purposes and ensure that assets and funds not used for personal gain.

  6. 3.6

    Health and Safety

    It is envisaged that the Group will conduct its business activities and operations in a safe manner and in an environment that prevents, to the extent possible, injury to its Employees, customers, suppliers and contractors. The Group will use its best endeavors to ensure a safe workplace and maintain proper occupational health and safety practices to commensurate with the nature of the Group’s businesses and activities and will seek to do this through continual improvement of environmental performance, protection and safety.

  7. 3.7

    Sexual Harassment

    Sexual harassment by any Employee is unacceptable. It is the Group’s policy to provide all Employees with a working environment free from any form of sexual harassment. Any questions concerning issues of such should be directed either to the Employees’ superior or the Human Resource Department. All such reports and/or complaints shall be treated with strictest confidence.

  8. 3.8

    Gifts, Loans and Entertainment

    A financial interest in a supplier, customer, agent or competitor is deemed to be a conflict of interest. An indirect interest can arise in which a person connected with that Employee has a financial interest in the supplier, customer, agent or competitor. “A person connected with the Employee” shall include his/her spouse, parents, siblings, offspring and the spouse of such offspring.

    All forms, manifestations and appearances of bribery are opposed. Therefore, no Employee shall accept any money, loans, gifts or favors of any substantial value. Advertising and promotional items (e.g. ballpoint pens, calendars, scratch pads. etc.) with no commercial value, which does not subject the staff of the Company or its supplier to any embarrassment or obligation, are not considered items of “substantial value” and may be accepted.

    If an employee of the Company receives unsolicited gratuities by any means whatsoever, he/she shall:

    • Notify his/her superior;
    • Complete the appropriate documentation to return the item(s) to the giver; and
    • Return the item(s).

    The exchange of social amenities between suppliers and business relationship in the best interests of the Company, any representative of a company with which it does business is permissible.

    Luncheon and dinner conferences with suppliers are sometimes necessary and desirable. Out of courtesy to suppliers, the Company representatives will pay for these meals on a reciprocal basis, as appropriate. Excessive entertainment of any sort is prohibited. In all matters of this sort, the Company is concerned about the possible appearance or suspicion of undue influence. The general rule is to be “beyond reproach”. Gifts and lavish entertainment are not desired and are not conditions for doing business with the Company.

    We are committed to mutual beneficial relationships based on honesty and respect:

    • Acceptance of cash gifts by the Employees is not allowed. The only exception to the cash gifts policy is giving/ receiving of very nominal value amount (RM 10.00 or less) in accordance with local custom such as ang pow at Chinese New Year;
    • Non-cash gifts to the Employees are inappropriate. Item of nominal promotional value (RM100 or less) may be accepted on an infrequent basis but gift giving is discouraged;
    • Gifts in the form of commissions, share in profits, gift certificates, travel or other payments, loans or advances: materials, services, repairs or improvements at no costs or unreasonably low prices: gifts of merchandise of more than nominal value (RM100.00 or less) are strictly prohibited;
    • Entertainment must have a clear business purpose, must not be extravagant and must be capable of being reciprocated by the Employees; or
    • Sponsorship of motor sports / events / holiday packages must be communicated and rendered at company-to-company level only, if any.
  9. 3.9

    Abuse of Power

    It is envisaged that the Employees must never use one’s position of power in an abusive way. This abuse of power can take many forms such as taking advantage of someone, gaining access to information that shouldn’t be accessible to the public, or just manipulating someone with the ability to punish them if they don’t comply.

  10. 3.10

    Anti-Money Laundering

    It is envisaged that the Group must never participate in any form of money laundering in its conduct of business activities.

  11. 3.11

    Anti-Corruption and Bribery

    The Group must never use improper means to influence another person’s business judgements. The Company must never provide bribes or other improper benefits to another person in order to retain and obtain businesses.

4. Reporting of Violations of The Code

Any Employee who knows of, or suspects, a violation of the Code, is encouraged to whistle blow or report the concerns through the Whistleblowing Policy. The provision, protection and procedure of the Whistleblowing Policy for reporting of the violations of the Code are available in Human Resource Manual, a manual issued to all new employees. No individual will be discriminated against or suffer any act of retaliation for reporting in good faith on violations or suspected violations of the Code.

5. Review of The Code

The Board will monitor compliance with the Code and review the Code regularly to ensure that it continues to remain relevant and appropriate.

6. Questions About This Code

Questions about the Code and its application by Employees should be directed to their Manager or Human Resource Department.

Background

Sustainability involves using resources more efficiently and in ways benefit the environment, customers, business and local communities. The misison of Jetson will be attained responsibly by carrying out its activities in a manner that achieves a balance between the social, economic and environmental dimensions of sustainability.

Sustainability Policy

Sustainability involves using resources more efficiently and in ways which benefit the environment, customers, business and local communities. The mission of Jetson will be attained responsibly by carrying out its activities in a manner that achieves a balance between the social, economic and environmental dimensions of sustainability.

Jetson is committed to ensuring the best possible economic, social and environmental outcomes for all those whom Jetson’s activity influences, including the communities in which Jetson operate, all direct and indirect employees of Jetson (including sub-contractors, business partners, investors) and, as far as practicably possible, organisations within the Company’s supply chain. Each person at Jetson is responsible for implementing and maintaining the principles of this Sustainability Policy.

Our Sustainability Policy is based upon the following principles:

  1. Comply with, and exceed where practicable, all applicable legislation, regulations and codes of practice.
  2. Promote healthy and safe environment to our employees and to the communities in which we operate.
  3. Apply high ethical business standards and best practice principles and methods.
  4. Efficient use of energy and natural resources.
  5. Respect the rights and values of the communities where Jetson operates, and strive to achieve challenging targets in social and environmental improvements.
  6. Provide open, timely and clear reporting on our performance against goals and targets.
  7. To continually strive to improve our sustainability performance.

Introduction

The Board of Directors, Senior Management and Employees of Kumpulan Jetson Berhad (“Jetson” or “the Company”) and its subsidiaries (collectively refer to as “the Group”) are committed to show high exemplary corporate conducts. The Code of Ethics and Conduct of Jetson (“the Code”) required Directors, Senior Management and Employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As such, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. In line with the above commitment, this Whistleblowing Policy (“the Policy”) is established to provide an avenue for all Directors, Senior Management and Employees of JETSON to disclose any improper conduct and to provide protection for them who report such allegations.

The Policy should be read in conjunction with the Code.

Reporting Responsibility

It is the responsibility of all Directors, Senior Management and Employees to comply with the Code and to report violations or suspected violations in accordance with the Policy. The possible violations may cover improprieties such as corruption, bribery, criminal offences, fraud, miscarriage of justice, endangerment of employees’ health and safety, failure to comply with regulatory/legal obligations and financial reporting irregularities, just to name a few.

No Retaliation

No director, senior management or employee who acts in good faith reports a violation of the Code shall suffer harassment, retaliation or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. The Policy is intended to encourage and enable employees and others to raise serious concerns within the Group prior to seeking resolution outside.

Reporting Violations

The Code addresses the Group’s open-door policy and suggests that Employees share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, an Employee’s supervisor is in the best position to address an area of concern. However, if Employees are not comfortable speaking with their supervisor or the Employees are not satisfied with their supervisor’s response, they are encouraged to speak with someone in the Group Human Resources Department or anyone in Management whom they are comfortable in approaching. Supervisors and managers are required to report suspected violations of the Code to the Compliance Officer, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when the Employees are not satisfied or uncomfortable with the following the Group’s open-door policy, individuals should contact the Compliance Officer directly.

Compliance Officer

The Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his discretion, shall advise the Executive Director and/or the Risk Management and Audit Committee of the Company (“the Committee”). The Compliance Officer has direct access to the Committee and is required to report to the Committee on compliance activity as and when necessary.

The Compliance Officer is the Chairman of the Committee.

Accounting and Auditing Matters

The Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Compliance Officer shall immediately notify the Committee of any such compliant and work with the Committee until the matter is resolved.

Acting In Good Faith

Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offence.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Compliance Officer will notify the sender and acknowledge receipt of the reported violation or suspected violation within seven (7) working days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Report On The Concerns

Any concern should be reported to the Chairman of the Committee. Channels of reporting to the Chairman of the Committee are as follows:

  1. Via email:
    Email to the Company Secretary via cosec@jetson.com.my for onwardtransmission to the Chairman of Risk Management and Audit Committee;
    or
  2. Via mail:
    Mark “Strictly Confidential – To be opened by Chairman of Risk Management and Audit Committee only” and send the report to:

    Kumpulan Jetson Berhad
    11th Floor, Menara Tokio Marine Life
    No. 189, Jalan Tun Razak
    50400 Kuala Lumpur

    Attention: Chairman of Risk Management and Audit Committee