SEGMENT KEY INTERNAL CONTROL ELEMENTS INTERNAL CONTROL SYSTEM Policies and Procedures Elements of internal control have been embedded and documented in the form of policies and procedures. A set of Group level policies and procedures complete with clear responsibility and accountability are maintained and accessible to employees via an internal portal. To strengthen consistent revision and adoption of Group’s policies and procedures, the Risk and Business Process Management Department has an oversight in the customisation and adoption of internal control policies across the Group. The approved policies and procedures will be reviewed and updated on a regular basis to ensure continuous improvements in operational efficiency while taking into consideration the changing operational profile, risks and internal control measures. Code of Conduct The Code of Conduct contains policies and guidelines relating to the standards and ethics that all employees are expected to adhere to in the course of their work. It is designed to maintain discipline and order in the workplace among employees of all levels. It also sets out the circumstances in which such employees would be deemed to have breached the Code of Conduct and the actions that can be taken against them if they do so. All employees are strictly required to adhere to the Group’s Code of Conduct in order to ensure a high level of discipline and integrity in carrying out duties. Anti-Bribery and Anti-Corruption Framework and Policy (“ABAC”) Following the enforcement of Section 17A of the Malaysian Anti-Corruption Commission Act 2009 and the Malaysian Anti-Corruption Commission (Amendment) Act 2018 that took effect on 1 June 2020, the Board had on 29 May 2020 approved the ABAC to ensure that adequate procedures are in place to prevent persons associated to the Group from undertaking such conduct of corruption and bribery. Any type of corruption and bribery of any nature, directly or indirectly, in order to influence any type of decision that may result in an undue benefit or advantage to DNeX Group will not be tolerated. The key features of the ABAC are measures established to control such misconduct at strategic, tactical and operational levels. It outlines the actions that need to be taken to prevent, detect and report potential threats and any corruption risks. It serves to reinforce the Group’s commitment to good governance and transparency, and shall further guide how employees and related parties shall continue to conduct business with honesty, fairness and high ethical standards, and not allowing certain types of behaviour contrary to commercial integrity which can compromise the Group’s reputation. Whistleblowing Framework and Policy The Whistleblowing Framework and Policy aims to provide a structured mechanism for the Group’s employees and any reporting parties to raise or report any suspected or known misconduct. The Whistleblowing Framework and Policy is administered by a Whistleblowing Committee and disclosure via a Whistleblower Report Form can be made to the established channel. Consistent with the need to conduct adequate investigation, the whistleblower’s identity and report will be treated by the Group as confidential to the highest extent possible. DAGANG NeXCHANGE BERHAD 144 STATEMENT ON RISK MANAGEMENT AND INTERNAL CONTROL
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