Whistleblowing Policy

  1. Definition
  2. 3A or Company:Three-A Resources Berhad (Co no. 481559-M)
    3A Group:Three- A Resources Berhad and its subsidiaries, collectively
    Whistleblowing Policy:Policy

  3. Purpose
  4. The Whistleblowing Policy is intended to support the 3A Group’s core values, corporate governance compliances and ethical standards in its dealing. 3A places high value on the level of trust and integrity of its employees within the 3A Group. By creating an atmosphere of openness and trust, 3A Group encourages the employees to use internal mechanisms for reporting any malpractice, illegal acts, omissions and to raise concerns prior to seeking resolution outside the Company.

    In line with this, 3A Group has adopted a Whistleblowing Policy that outlines the commitment to ensure that employees and other stakeholders are able to raise concerns regarding any illegal conduct or malpractices, corruption, harassment, discriminatory treatment, illegal acts or omission at work, and to have such concerns properly investigated.

    The Policy sets out the mechanism and framework by which the employees, stakeholders, and any other individuals or organisation who have dealing with the 3A Group can confidently address the concerns or complaints in a responsible manner without fear of discriminatory treatment.

  5. Scope
  6. This Policy applies to the Company and its subsidiaries. All employees, shareholders, directors, vendors, consultants or any parties with a business relationship with the 3A Group are encouraged to disclose any wrongdoing that may adversely impact the Company.

  7. Policy

    1. All employees and other stakeholders are encouraged to make any disclosures, complaints or concerns openly and honestly.
    2. All disclosures made under this Policy will be dealt in a confidential manner. Disclosures received under anonymity will not be entertained to prevent invalid malicious reporting, exploitation and victimisation.
    3. The whistle-blower is required to identity himself or herself and provide contact information in his or her report. This will facilitate the investigator to obtain further information, if required and to communicate on results of investigation.
  8. Improper Conduct

    The following shall constitute improper conduct under this Policy.

    1. Incidents of fraud, corruption or bribery;
    2. Breach of the Company’s or 3A Group’s policies, practices, procedures or other rules of conduct;
    3. Conduct activity which breaches any law or regulatory obligations;
    4. Any situation which poses a danger to any individual, health, safety or environment; and
    5. Improprieties in matters of financial reporting
  9. Communication

    1. Disclosure of information should promptly be made by the whistleblower to one or more of the following persons of 3A Group.
    2. Mr Fang Chew Ham
      (Managing Director)
      Email: fang.chewham@three-a.com.my
      Mr Fong Chu King
      (Executive Director)
      Email: fong.chuking@three-a.com.my
      Dato’ Mohd Nor Bin Abdul Wahid
      (Independence Non-Executive Chairman)
      Email: datomohdnor@gmail.com
      Mr Derek Liew
      (General Factory Manager)
      Email: derek.liew@sssfi.com
      Ms Jessica Fang
      (Executive Director)
      Email: jessica.fang@three-a.com.my
    3. Disclosure or complaint can be made through email or mail addressed to any of the above persons. The mailing address is as follows:
      AL 308, Lot 590 & Lot 4196
      Jalan Industri, U19
      Kg Baru Sungai Buloh
      40160 Shah Alam, Selangor

    5. The whistleblower will be informed of the person who is handling the matter, and if there is any further information or assistance required.
  10. Required Evidence

    The whistleblower must provide the disclosure or complaint in writing, sufficient information of the conduct, identity of the suspected person being involved, date of the occurrence and the suspected victim (if any).

    The whistleblower must have first-hand information or knowledge of the facts (i.e. information obtained from third party or ‘hearsay’ will not be entertained). However, the whistleblowers should not be discouraged from making a disclosure if they are unsure whether there is sufficient evidence to support their allegations.

  11. Confidentiality & Protection

    1. The whistleblower must identify himself or herself upon submitting a disclosure or complaint in good faith.
      1. The whistleblower will be protected from any reprisal within the 3A Group as a direct consequence of the disclosure. Reprisal includes disciplinary action, warning, demotion, suspension or termination of the employment;
      2. The identity of the whistleblower shall be protected and kept confidential unless otherwise required by law or for the purpose of any proceedings by or against the 3A Group;
      3. The identity and personal information of the whistleblower and the alleged wrongdoer may be revealed to persons involved in the investigation or any other process.
    2. The protection under 8.1 will be accorded by the 3A Group provided that the whistleblower satisfies all the following conditions:
      1. The disclosure or complaint is done in good faith;
      2. The whistle-blower has not communicated the disclosure to any other party not related to the disclosure;
      3. The whistle-blower is aware that the disclosed information or allegation is true; and
      4. The disclosure made is not for any personal interest or gain.
    3. Any false, malicious or defamatory allegation may constitute as gross misconduct where appropriate disciplinary action may be taken by 3A Group.
    4. Human resource and industrial relation related issues are excluded from the operation of this Policy as there are other mechanisms for raising such complaints.
  12. Procedure

    1. All disclosures or complaints received will be placed before the Whistleblowing Committee for its action.
    2. The Whistleblowing Committee shall comprise of the following members:
      1. Executive Directors
      2. Independent Non-Executive Director
      3. Key Management Personnel
      4. Senior Manager
    3. The authorities and functions of the Whistleblowing Committee are as follows:
      1. Receive, process, investigate and determine the genuineness of the disclosure or complaint submitted;
      2. Conduct initial enquiry on disclosure or complaint received;
      3. Dismiss any disclosure or complaint if the same has no basis or merit or unrelated matter to be dealt with under this Policy;
      4. Nominate the investigation officers to investigate any disclosure or complaint;
      5. Review the findings made by the investigation officers in respect of any disclosure or complaint; and
      6. Decide on the appropriate action to be taken to address the disclosure or complaint.
    4. If any of the Whistleblowing Committee members is the suspect being involved in the improper conduct, he or she will be abstained immediately from attending the meeting.
    5. The assigned investigators must take all reasonable steps to ensure the investigation is fair and unbiased. All the detailed records of evidence gathered, interviews conducted and any other records received which affect the outcome of the investigation will be kept safely.
  13. Reporting

    1. Upon conclusion of the investigation, the Whistleblowing Committee will present the findings and outcome to the Audit Committee of the Company.
    2. Subject to the legal constraint, the whistle-blower and the alleged wrongdoer will be notified of the outcome of the investigation. The notification letter will be signed off by the Committee member
    3. The Human Resource Department of 3A Group will be responsible to institute the necessary disciplinary action based with the outcome of the investigation.
    4. If the investigation outcome involves any members of the Board of Directors, the action will be deliberated by the Board of Directors of 3A Group.
    5. If the whistleblower is dissatisfied with the outcome of the investigation, the whistleblower can submit a detailed report explaining his or her concerns, and re-investigation is subject to the decision of the Whistleblowing Committee,
  14. Review of Policy

    The Audit Committee or the Board of Directors of 3A Group can amend, modify or revise this policy unilaterally at any time without notice. Amendment, modification or revision may be necessary, among other reasons to maintain the compliance of the relevant laws and regulations and to accommodate organisational change within the 3A Group. Any amendment, modification or revision to this policy will be communicated to all employees of 3A Group.


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