Opulent is committed to the highest standard of integrity, openness and accountability in the conduct of its businesses and operations. It aspires to conduct its affairs in an ethical and responsible manner.

This policy is to provide an avenue for all employees to disclose any improper conduct in accordance with the procedures as provided for under this policy and to provide protection for employees who report such allegations.

Nevertheless, any financial or business decisions taken by the company shall not be regarded in this policy.


This policy applies to all employees of Opulent Group. This policy is designed to facilitate all employees of Opulent Group to disclose any improper conduct (misconduct or criminal offence) through internal channel. Such misconduct or criminal offences include the following:

    i. Financial malpractice or impropriety or fraud
    ii. Failure to comply with a legal obligation or Statutes
    iii. Dangers to Health & Safety or the environment
    iv. Criminal activity
    v. Improper conduct or unethical behavior
    vi. Demanding, offering or accepting bribes direct or indirect or illegal gratification
    vii. Attempts to conceal any of these

Protection to Whistleblower

A whistleblower will be accorded with protection of confidentiality of identity, to the extent reasonably practicable. In addition, an employee who whistleblows internally will also be protected against any adverse and detrimental actions for disclosing any improper conduct committed or about to be committed within Opulent, to the extent reasonably practicable, provided that the disclosure is made in good faith.

Such protection is accorded even if the investigation later reveals that the whistleblower is mistaken as to the facts and the rules and procedures involved.

Anonymous Allegations

Any employee who wishes to report improper conduct is required to disclose his identity to the Company in order for the Company to accord the necessary protection to him. However, the Company reserves its right to investigate into any anonymous disclosure.

Procedure of Making a Disclosure

Reporting Channel

Disclosure can be made to ANY of the following reporting channels, in strict confidential manner:

    i. Online submission through our web form
    ii. Directly report to HR Manager

Content of Disclosure

Any disclosure made herein should contain the following information:

    i. Details of the person(s) involved
    ii. Details of the allegation - nature of allegation, time and venue of the alleged misconduct/wrongdoing took place
    iii. Other relevant information
    iv. Any supporting evidence if available

Only genuine concerns should be disclosed. The Whistleblower is responsible to ensure that the disclosure is made in good faith and free from any malicious intent. In addition, any disclosure which is found to be frivolous or vexatious will not be entertained. If the investigation later revealed that the disclosure was made with malicious intent, appropriate action can be taken against the Whistleblower.

The Whistleblower who wishes to withdraw his/her disclosure is required to write to the relevant Reporting Channel and provide reason(s) for the withdrawal. Nevertheless, the Company reserves the right to proceed with investigation on the subject matter of the disclosure.

Upon the completion of the whistleblowing process and procedures, the whistleblower will be accorded the privilege to be notified on the outcome of the disclosure.

Process of Making Disclosure

    Step 1: Whistleblower to submit the disclosure
    Step 2: Whistleblowing committee to administer and evaluate the disclosure
    Step 3: Whistleblowing committee conducts investigation and decide on the next course of action
    Step 4: HR takes neccesary action i.e. disciplinary action
    Step 5: Notify whistleblower on the outcome of disclosure