This Whistle Blowing Policy (WBP) is made pursuant to the Amended listing rules and the Code of Corporate Governance. The Policy are established guidelines, wherein employees of the Company, contractors and the general public can report “SERIOUS” actual or suspected concerns or happenings, considered unethical, inappropriate or illegal.

Policy Objective:

The Company is committed to high moral, legal and ethical standards in the conduct of its business. This policy therefore seeks to encourage the reporting of stakeholders’ concerns internally and to enable the Company review and address inappropriate actions or conducts.

It also provides an avenue where integrity, honesty and best practice, can be adhered to, in business dealings. Whistle Blowing involves an individual making a disclosure, in the interest of A.Y.M Shafa Holdings Limited and/or its stakeholders, regarding suspected fraud, misconduct, or dangers which have occurred or may be occurring at or during the course of work for A.Y.M Shafa Holdings Limited.

A whistleblower is an individual or person who exposes secretive information or activity that is deemed unethical, illegal, or not correct within A.Y.M Shafa Holdings Limited or its business engagements. The Whistle Blowing Policy is an objective, impartial and fair mechanism for addressing stakeholder’s complaints and a monitoring mechanism for addressing serious WBP concerns. The Company commits to attend promptly, to complaints, concerns and stakeholders’ feedback.

Application:

This Policy applies to all employees, job applicants, vendors, service providers, customers, contractors, and other stakeholders of A.Y.M Shafa Holdings Limited. Reporting Procedure: Incidents of suspected fraud and misconduct should be reported as soon as such incidents are identified as this makes it easier for management to respond effectively. Delays in reporting concerns may result in damages to reputation and/or significant losses to the company. The whistleblower shall promptly report any serious, actual or suspected concern to the dedicated whistleblower email address whistleblower@aymshafaholdings.com. The whistleblower may also report direct to the highest level of management or to a member of the board in the event that the whistleblower is reluctant or uncomfortable with reporting the incident to his/her Line Manager or Head of Department. Whistleblowers are also encouraged to provide any information such as the parties involved, nature and details of the incident, relevant dates, and any other useful evidence, which may assist in the investigation of the reported incident.

All serious complaints, concerns reported indicating fraud, misconduct, or danger anonymously through the internal or other channels shall be promptly attended to.

Act of Good Faith:

The whistleblower shall ensure that the report of serious complaints, concerns or unethical behavior, is made in good faith and is not intended to malign or damage the reputation of another person or the Company and is not made with malicious intent. There shall be no retaliatory action against a whistleblower for any report made in good faith.

However, any act done out of malice or without good faith will be subject to sanctions, discipline or legal action, to protect the other party or the Company’s reputation.

Confidentiality:

A.Y.M Shafa Holdings Limited will ensure that all potential whistleblowers are not hindered in any way in reporting suspected and/or identified incidents.

Therefore, the identity of the whistleblower shall be kept confidential at all times.

Protection of Whistleblowers:

A.Y.M Shafa Holdings Limited will ensure that employees who report concerns are given the level of attention and support required.

Therefore, regardless of reservations, which potential whistleblowers have due to the fear of retaliation, A.Y.M Shafa Holdings Limited encourage its employees in reporting genuine concerns under this Policy.

Employees will not be subjected to any negative treatment as a result of blowing the whistle. Employees are advised not to exhibit any form of retaliation or negative treatment towards any whistleblower.

Investigation of Reports:

When a concern has been reported, the Head of Human Resources/ Compliance Officer or any other recipients of the incident report will be responsible for determining an appropriate investigation plan with the Group MD/COO or Chairman/CEO as applicable.

The Investigation team will ensure that all complaints, concerns or unethical behavior are investigated thoroughly, appropriate recommendations are made and the issue resolved. Where an allegation against an employee is found to be valid, such an individual will be subject to disciplinary action in line with the Company’s disciplinary policy and procedure.