1. INTRODUCTION

All employees of the Damansara Realty Berhad (DBhd) and its subsidiaries ('the Group') play an important part in maintaining the highest level of corporate ethics within the Group, and have a professional responsibility to disclose any known malpractices or wrongdoings (hereon refrerred to as "Concerns").

2. SAFEGUARDS

A person or entity making a protected disclosure is commonly refrered to as a "Whistleblower". Whistleblowers provide initial information related to a reasonable belief that an improper activity has occurred.

Whistleblowers are protected against being dismissed or penalised and Dbhd shall consider mitigating circumstances if the Whistleblower himself/herself is involved in the activity that he / she reports.

3. CONFIDENTIALITY

Every effort shall be made to treat the Whistleblower's identity with appropriate regard for confidentiality, The Group gives the assurance that it shall not reveal the identity of the Whistleblower to any third party not involved in the investigation or prosecution of the matter. The only exception to this assurance relates to an overriding legal obligation to breach confidentiality. The Group is obligated to reveal confidential information relating to a whistle-blowing report, if ordered to do so by a court of law.

4. PROCEDURES

4.1 Process for Disclosure

i) Impropriety

This policy covers improprieties or irregularities, suspected fraud or criminal offences, breach of confidentiality and failure to comply with statutory or regulatory requirements.

ii) Reporting

Managers, officers and employees in supervisory roles shall report to the reporting person(s) on any allegations of suspected improper activities.

Such disclosures, including those relating to financial reporting, unethical or illegal conduct, may be reported directly to:

           The Company Secretary
           Company Secretarial Department
           Lot 10.3, Level 10
           Wisma Chase Perdana
           Jalan Semantan
           50490 Kuala Lumpur

          Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Employment-related concerns may be reported to:

           Head of Human Resources
           Lot 10.3, Level 10
           Wisma Chase Perdana
           Jalan Semantan
           50490 Kuala Lumpur 

           Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Disclosure should be in writing and forwarded in a sealed envelope to the abovementioned contact person(s) labelling with a legend such as "To be opened by the Audit Commitee Chairman or Head of Human Resources only".

iii) Handling of a reported allegation

The action taken by the Group in response to a report of Concern under this policy shall depend on the nature of the concern. The audit commitee Chairman and/or the Group CEO shall receive information on each report of Concern and follow-up information on actions taken.

4.2 Investigator

The Internal Auditor shall be the named Investigator unless the Audit Committee Chairman and/or the Group CEO assigns / appoints another Investigator. Investigators must be impartial and independent of all parties concerned.

The Investigator is required to report all concerns raised, the status of all pending and on-going investigations, and any action taken or to be taken as a result of the investigations, to the Audit Committee Chairman and/or the Group CEO.

4.3 Inquiries

Initial inquiries shall be made to determine whether an investigation is appropriate, and the form that it should take. some concerns may be resolved without the need for investigation.

if an investigation leads the Investigator to conclude that a crime has probably been committed, the results of the investigation shall be reported to the police or other appropriate law enforcement agency.

If an investigation leads the Investigator to conclude that the suspect has engaged in conduct that may be a violation of the Group's code of Ethics or Conduct, the results of the investigation shall be reported to the Head of Human Resources and/or the Group CEO in accordance with the administration of discipline. Any charges of misconduct brought as a result of an investigation under this policy shall comply with the established disciplinary procedures.

5. MONITORING AND REVIEW OF POLICY

The Board should ensure that the policy meets the objectives of relevant legislations and remain effective for the Group.

This policy shall be reviewed annually by the Board and, as and when the need arises.

Dated: 1 January 2015