This Policy aims to achieve the following :

2.1Setting tone – affirms the Board’s stance against any fraud committed against the Group and create awareness among the employees and business associates (including agents, representatives, clients/customers, vendors, shareholders etc.).
2.2 Framework – establishes or provides a framework for the Group and its employees to deal with actual and suspected fraud incidents in a consistent manner.
2.2 Procedures – outlines the procedures for fraud response, investigation, monitoring and reporting.
2.2 Responsibilities – assigns responsibilities for fraud detection, investigation and development of internal controls against frauds.

3.1 This Policy shall apply to all level of personnel of the Group and its business associates.
3.2 Actions constituting fraud include but not limited to :

• Misappropriation of financial and non-financial assets (including theft of cash/funds, equipment, stocks, physical assets; Forgery or unauthorised alteration to cheques and other paying instruments.).
• Disclosing confidential information to outsiders for personal gain;
• Deceiving customers into making payments to personal accounts.
• Manipulations, falsifications and alterations of the documents/records of the Group.
• Recording transactions without substance.
• Falsifying claims (including expenses, medical leaves, overtime, allowances, salaries or wages etc.).
• Wilful or malicious damage or destroy Group’s assets.
• Insider trading.
• Bribery and corruption (e.g. getting undisclosed kickbacks or accepting gifts or hospitality as inducement for giving orders to vendors.)
• Blackmailing.
• Deliberate material accounting misstatement.
• Other inappropriate conducts resulting in gaining benefits at the expense of the Group or its subsidiaries.

The Board of Directors is committed to preventing and addressing all significant acts of fraud against the Group. All employees shall perform their duties with honesty, integrity and in an ethical manner. All actual or suspected frauds shall be reported and handled according to the procedures laid down in this Policy, or according to the Group’s Whistle-Blowing Policy which is available at the Group’s corporate website.

6.1 Making a Report

Information gathered and investigation results will not be disclosed and discussed with anyone other than those with a legitimate need to know. This is to avoid unnecessary damage to the reputation of the accused wrongdoers who may be found innocent of wrongdoings by the investigation.

A Group Fraud Register shall be maintained by the Group Internal Audit Department, which will be used as a basis for reporting incidents of suspected or actual fraud and outcomes of investigation undertaken into suspected fraud, including the value of any loss to the Company

The Audit Committee is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed at least once every 2 years.