This whistleblowing policy (hereinafter referred to as “this Policy”) sets out the mechanism and framework by which employees and any other individuals or organizations who have dealings with TH Plantations Berhad and its group of companies (“THP”) can raise concerns on wrongdoings in a responsible manner at the earliest opportunity without fear of reprisal and to have the concerns promptly investigated and resolved.

Scope of Reporting

A disclosure (“Disclosure”) may be made if it relates to one or more of the following wrongdoings by any persons in the conduct of THP’s business or affairs (“Wrongdoing”):

• Bribery, fraud, corruption or abuse of power;

• Criminal offences;

• Misappropriation of funds or assets, theft or embezzlement;

• Gross mismanagement within THP;

• Financial irregularity or impropriety;

• Conflict of interest without disclosure and approval;

• Breach of THP’s Code of Conduct/Employee Handbook, including sexual harassment and other abuses of human rights;

• An act or omission which creates a substantial and specific danger to the lives, health or safety of THP’s employees or the public or the environment;

• Failure to comply with legal and regulatory obligations;

• Knowingly assisting, directing or advising a person to commit any of the above Wrongdoings;

• Deliberate concealment of any of the above Wrongdoings; and

• Any other detrimental wrongdoing which the nature of the wrongdoing is subject to the absolute discretion of the BARGC and/or the Board.

Reporting Channels

All disclosures pursuant to this Policy are to be made through the dedicated whistleblower channels, provided by an independent external party, as follows:

• Telephone hotline: 03-2616 7115; (Available during office hours, i.e. 9.00 am to 6.00 pm Monday to Friday, excluding public holidays in Kuala Lumpur)

• Email hotline: whistleblowing_thp@bdo.my; or

• Web portal: TH Plantations Ethics Line

Initial Disclosure

1. A Disclosure can be made in writing or orally.

2. A Disclosure shall include at least the following particulars:

   1. Details of the Whistleblower:

      • If the Whistleblower is an employee of THP, his or her name, designation and contact numbers; or

      • If the Whistleblower is not an employee of THP, his or her name, name of employer and designation, relationship with THP, and contact numbers;

   2. Nature of the Wrongdoing;

   3. Background and details of the Wrongdoing;

   4. Identity of the alleged wrongdoer (s);

   5. Reason for believing the reported incident to be an issue/wrongdoing;

   6. Particulars of the witness(es), if any; and

   7. Documentary evidence, if any.

3. Given that the anonymity of the Whistleblower will be preserved, anonymous reports generally will not be entertained so as to prevent the abuse of the whistleblowing platform. However, THP reserves the right to investigate anonymous whistleblowing reports depending on the nature and gravity of the allegations in the report.

4. Any reports submitted outside the designated whistleblowing channels will not be subject to/covered by this Policy.

Protection

Upon making a disclosure in good faith, based on reasonable grounds and in accordance with the procedures pursuant to this Policy:

1. the Whistleblower will be protected from a reprisal within THP as a direct consequence of his or her disclosure; and

2. the Whistleblower’s identity will be protected at all times i.e. kept confidential unless otherwise required by law or for purposes of any proceedings by or against THP.

Any employees of THP or Other Persons who made, or are discovered to have made, a disclosure otherwise than in good faith and based on reasonable grounds will automatically lose the above protections (where applicable).

Whistleblowing Policy