Whistleblowing

Objective.

Opulent is committed to the highest standards 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 provides an avenue for all employees to disclose an improper in conduct in accordance with the procedures outlined herein and offers protection to those who report such allegations.

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

Scope.

This policy applies to all employees of Opulent in Malaysia.

This policy is designed to facilitate the disclosure of any improper conduct (misconduct or criminal offence) by all employees of Opulent Group throup internal channels.

Such misconduct or criminal offences include the following:

1. Financial malpractice or impropriety or fraud

2. Failure to comply with a legal obligation or Statutes

3. Dangers to Health & Safety or the environment

4. Criminal activity

5. Improper conduct or unethical behavior

6. Demanding, offering or accepting bribes direct or indirect or illegal gratification

7. Attempts to conceal any of these

Definitions.

Whistleblower refer to a person who report on a person or organization engaged in an unethical activity.

Responsibilities.

1. All employees are responsible in helping to create a climate at work where any improper conduct must be disclosure.

2. HR Manager is responsible to ensure the consistency of application through all necessary stage and respond on the whistleblowing.

Procedure.

Reporting Channel

Disclosure may made to ANY of the following reporting channels, in strictly confidential manner:

1. Online submission through web link

2. Online submission through company website

3. QR Code on RBA badge, Notice Board, Suggestion Box or Anti-Harassment Poster.

All whistleblowing submission shall be redirect to HR Manager and cc to the company Director.

Content of Disclosure

Any disclosure made herein should contain the following information:

1. Details of the person(s) involved;

2. Details of the allegation

   1. Nature of allegation;

   2. Where and when the alleged misconduct/wrongdoing took place;

3. Other relevant information; and

4. Any supporting evidence if available

Only genuine concerns should be disclosed. The Whistleblower is responsible to for ensuring 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.

A Whistleblower who wishes to withdraw his/her disclosure is must submit a written request to the relevant Reporting Channel, stating the reason(s) for the withdrawal. Nevertheless, the Company reserves the right to proceed with an investigation into the subject matter of the disclosure.

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

Protection to Whistleblower.

A whistleblower will be accorded protection of identity confidentiality, 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.