• Conflict of Interest (“COI”) Declaration Procedure The Conflict of Interest (“COI”) Declaration Procedure provides a structured process for employees to declare actual, potential, or perceived conflicts of interest in alignment with the Conflict of Interest (“COI”) Policy. This procedure outlines the steps for identifying, disclosing, and addressing conflicts of interest to ensure they are managed effectively and transparently. By adhering to this procedure, UEM Edgenta reinforces its commitment to ethical conduct, accountability, and the protection of the Group’s integrity in all business activities. • Anti-Bribery & Anti-Corruption (“ABAC”) Policy Statement UEM Edgenta is committed to upholding its core values by fostering a culture of integrity, ethics, and accountability in all aspects of our operations. This commitment extends to every stakeholder including directors, officers, and employees, who are required to adhere to the highest ethical standards in conducting business. The ABAC Policy Statement reinforces a zero-tolerance approach towards bribery and corruption. It ensures that all business dealings, relationships, and operations comply fully with laws and regulatory requirements in all jurisdictions where UEM Edgenta operates. • Anti-Bribery & Anti-Corruption (“ABAC”) Guide In respect of the ABAC Policy Statement that takes a zerotolerance approach to bribery and corruption, reflecting our unwavering commitment to the highest standards of ethical conduct in all business dealings and relationships, the ABAC Guide serves as a practical resource for providing essential guidelines in preventing bribery and corruption. It outlines clear standards for ethical behavior, emphasising that all directors, officers, and employees must not act corruptly in our business dealings. This guide reinforces our collective responsibility to uphold integrity and accountability in every aspect of our operations. • No Gift Policy At UEM Edgenta, the No Gift Policy is a cornerstone of our commitment to upholding the highest standards of integrity and ethical conduct. This policy is designed to eliminate both actual and perceived conflicts of interest, ensuring that all business decisions remain fair, transparent, and free from undue influence. By strictly prohibiting the acceptance of gifts, we ensure that our employees, stakeholders, and partners adhere to principles that promote fairness, transparency, and unbiased decision-making. This policy serves as a safeguard to protect the integrity of our employees, stakeholders, and business partners, fostering an environment of transparency and impartiality. • Anti-Bribery Management System (“ABMS”) Manual The Anti-Bribery Management System (“ABMS”) Manual outlines the requirements of the internationally recognised MS ISO 37001:2016 standard. It serves as a comprehensive framework for implementing a robust management system to prevent, detect, respond to, and address bribery and corruption within UEM Edgenta. This manual ensuring compliance with global standards while strengthening integrity, accountability, and ethical business practices across our organisation. • Whistleblowing Policy The Whistleblowing Policy underscores UEM Edgenta’s commitment to fostering a culture of transparency and accountability. It encourages employees, stakeholders, and other parties to report any suspected wrongdoing or misconduct in good faith. This policy ensures that all reports are handled with the utmost confidentiality, protecting the identity of whistleblowers and safeguarding them against any form of retaliation. By providing a secure and fair reporting mechanism, this policy strengthens our ethical governance and reinforces trust within the organisation. • Whistleblowing Procedure The Whistleblowing Procedure at UEM Edgenta establishes a clear and confidential mechanism for employees, stakeholders, and members of the public to report any actual or suspected misconduct, malpractice, or violation of the Group’s policies and procedures. Reports can be submitted through our dedicated and secure “Speak-up Channel” which ensures confidentiality and facilitates a transparent and effective process for addressing concerns. This procedure reflects our unwavering commitment to ethical governance and maintaining trust across all levels of our organisation. • Investigation Procedure UEM Edgenta’s Investigation Procedure establishes a structured and consistent process for assessing and investigating allegations or violations of the Group’s Code of Conduct, policies, procedures, and applicable regulations. This procedure ensures that investigations are conducted fairly, outcomes are documented systematically and in a timely manner, and any required corrective action or escalation to enforcement agencies are executed effectively. 255 GOVERNANCE
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