This Anti-Bribery and Anti-Corruption Policy (this “Policy”) applies to all directors, officers and employees, collectively “personnel” of Pop Bio Sdn. Bhd. and all of its controlled subsidiaries (collectively the “Company”), unless such a controlled subsidiary has adopted its own Anti-Bribery and Anti-Corruption Policy that is consistent with the provisions of this Policy.

This Policy reflects the standards to which the Company expects any person or entity that performs services on behalf of the Company to adhere to when acting on the Company’s behalf. Such persons or entities acting on the Company’s behalf could include business associates, partners, agents, intermediaries, representatives, suppliers, contractors, third party service providers and, consultants (collectively “Third Parties”).

All the Company’s Personnel as well as Third Parties are expected to read and become familiar with this anti-bribery and anti-corruption policy and may be required, from time to standards by signing the Compliance Certificate that appears at the end of this Policy.


The purpose of this Policy is to reiterate the Company’s commitment to conducting its business with honesty and integrity and in full compliance with applicable anti-bribery or anti-corruption laws, including, but not limited to, those applicable in the Malaysia such as the Malaysian Anti-Corruption Commission Act 2009 and its 2018 amendment (MACC Act). In the event that local laws are more restrictive than this policy, the more stringent local requirement shall apply.


a) Bribery and corruption are strictly prohibited. A “bribe” is anything of value or “gratification” that is offered, promised, given or received by any party to influence a decision or to gain or reward an improper or unfair advantage for the benefit of the Company or any other party. “Corruption” is the abuse of power or position for private gain. Bribery and corruption can take many forms, including but not limited to the offering, provision or acceptance of:

– Cash payments;
– Loans or non-arm’s length transactions;
– Phony jobs or “consulting” relationships;
– Kick-backs;
– Political contributions;
– Charitable contributions / donations;
– Employment opportunities or internships;
– Social benefits; or
– Gifts, travel, hospitality and the reimbursement of expenses.

The Company strictly prohibits all bribery or corruption, in any form whatsoever.

b) Do not make “facilitation payments”. Facilitation payments, directly or indirectly, are also a form of bribe and are, therefore, not permitted to be accepted or obtained. Attempts to accept or obtain or offering or attempting to offer facilitation payments from / to any person for themselves or for any other person are prohibited. Facilitation payments are small payments made to secure or speed up routine actions or otherwise induce public officials or other Third Parties to perform routine functions they are otherwise obligated to perform, such as issuing permits, approving immigration documents or releasing goods held in customs. This does not include legally required administrative fees or legally permitted fees to fast-track services. If you have a question about whether a particular payment is permitted under this Policy, please contact the CEO or internal legal counsel prior to making such payment.


Interactions with public officials require enhanced scrutiny and sensitivity. A “public official” is any person who is employed by or is acting in an official capacity for a government, a department, agency or instrumentality of a government, regulator, or a public international organization. This includes elected or appointed persons who hold legislative, administrative or judicial positions such as politicians, bureaucrats, civil servants, and judges. It also includes persons who perform public functions such as professionals working for public health agencies, water authorities, planning officials and agents of public international organizations such as the United Nations or World Bank. A “public official” also includes employees of government-owned or controlled businesses such as the manager of a state-owned public utility. There is increased sensitivity and scrutiny of dealings with public officials because this has traditionally been an area where bribery activity and corruption are more likely to occur. Be cognizant of these risks in your dealings and interactions with public officials and consider how your actions may be viewed. For example, payments, gifts or employment to close relatives of public officials may be treated by enforcement authorities as direct payments to the public officials and therefore may constitute violations of law. As a result, gifts to public officials are strictly prohibited and entertainment for public officials should be modest and reasonable. In addition, because interactions with public officials carry special risks under applicable anti-bribery and anti-corruption laws, contracts and payments to public officials should be reviewed carefully to determine what additional safeguards, if any, may be necessary to protect the Company. Please seek authorization from the CEO or internal legal counsel prior to entertaining, contracting with, or offering or making payments to public officials.


Any gifts given or received shall be modest and any entertainment given or received shall be proportionate and reasonable for the circumstances. Subject to the restrictions set out in the prior section relating to public officials, gifts given to or received from persons who have a business relationship with the Company are generally acceptable, if the gift is modest in value, is appropriate to the business relationship, is not given or received to gain an improper advantage or unfair influence and does not create an appearance of impropriety. No cash payment or cash equivalents should be given or received. Token gifts (not cash) in line with local custom and practice, are acceptable. Entertainment (e.g. meals, tickets to sporting events or theatre, rounds of golf) given to or received from persons who have a business relationship with the Company are generally acceptable, if the entertainment is reasonable in value, appropriate to the business relationship, infrequent, is not given or received to gain an improper advantage or unfair influence, does notcreate an appearance of impropriety and if a representative from the sponsoring organization (the party paying for the entertainment) is present at the event. Note that many jurisdictions have laws restricting entertainment of public officials or their close relatives.

All receipt of gifts and entertainment shall be registered with the human resources department via email within forty-eight (48) hours of receiving it or as soon as practically possible thereafter.

Gifts and entertainment (including meals) that are repetitive, no matter how small, may be perceived to be an attempt to create an obligation to the giver and should be avoided. Gifts or entertainment given close in time to when a decision impacting the Company’s business is being made may be perceived as a bribe in return for a favourable decision and should also be avoided. Please exercise good judgment in determining whether a specific gift item lies within the bounds of acceptable business practice.

Employees should not give or receive “big-ticket” items, such as travel, accommodations, conference fees, costs for road shows, or event sponsorships, without prior authorization from the CEO or internal legal counsel. If you are in doubt as to whether gifts or entertainment proposed to be given or received are proportionate and reasonable for the circumstances, please consult the CEO or internal legal counsel.


a) Do not offer contributions to political parties or candidates that might influence, or be perceived as influencing, a business decision. The making or offering monetary or in-kind political contributions to political parties, political party officials or candidates for political offices in Malaysia are strictly prohibited.

Please ensure that the Company not breach the law regarding political donations in any country, all political donations, no matter how small or insignificant, made on behalf of the Company (directly or indirectly) must be authorized in advance by the CEO or internal legal counsel. Political donations should not be made on behalf of the Company in countries in which the Company not have a presence.

Political donations made by individuals on their own behalf should comply with any applicable local laws and regulations. The Policy must be consulted and adhered to before making any political contributions in Malaysia on behalf of the Company or by individuals on their own behalf. Similarly, outside the Malaysia, local political contribution policies should be consulted and adhered to before making any political contributions in that geography.

b) Do not engage in any lobbying activities on behalf of the Company without specific authorization. The Company encourages its employees, officers and directors to take an active role in public service. However, any participation in this regard is to be undertaken as an individual and not as a representative of the Company. Lobbying activities generally include attempts to influence the passage or defeat of legislation and it may trigger registration and reporting requirements. In many jurisdictions, the definition of lobbying activity is extended to cover efforts to induce rule-making by executive branch agencies or other official actions of agencies, including the decision to enter into a contract or other arrangement. You may not engage in lobbying activities on behalf of the Company without the prior authorization from the CEO or internal legal counsel.


Do not solicit or offer donations to suppliers, vendors or public officials in a manner which communicates that a donation is a prerequisite for future business or that the offer of a donation is intended to obtain a business advantage. The Company encourages directors, officers and employees to contribute personal time and resources to charities and nonprofit organizations. However, unless the solicitation is supported by the Company, you are prohibited from using the Company’s resources to solicit donations as a subterfuge for bribery. Charitable donations or requests for charitable donations made by individuals on their own behalf should comply with any applicable local laws and regulations. If you are requested by a public official to make a personal donation to a particular charity, please seek authorization from the CEO or internal legal counsel.


Record all transactions in a complete, accurate and detailed manner so that the purpose and amount of the transaction is clear. In addition to prohibiting bribery and corruption, some anti-bribery and anti-corruption legislation requires proper record-keeping and the establishment and maintenance of internal controls. The purpose of these provisions is to prevent companies from concealing bribes and to discourage fraudulent accounting practices.
All the Company’s transactions must be recorded completely, accurately and with sufficient detail so that the purpose and amount of any payment is clear. No accounts or payments may be kept “off-book”. False, misleading, or artificial entries must never be made in the books and records of the Company for any reason.


Third Parties are not permitted to pay, offer, accept or request bribes on the Company’s behalf. The Company, together with any Third Party (as defined above) may be prosecuted for failing to prevent bribery by a person associated with it.

In this regard, due diligence shall be undertaken on Third Parties to establish their anti-bribery credentials, where warranted by the assessed level of risk. This could include informing these persons (and associated companies) of this Policy, meeting with them to better assess their character, and making commercially reasonable inquiries into their reputation and past conduct. Anti-bribery language should be included in Third Party agreements, where appropriate, in consultation with internal legal counsel.


The Company’s personnel have an obligation to adhere to this Policy. If you witness behavior on the part of the Company’s personnel or any Third Party that you believe may represent a violation of this Policy, you must promptly report it. The Company practices an open-door policy and encourages all personnel and Third Party(ies) to share concerns and suggestions which shall be addressed in an appropriate manner.

The Company takes all reports seriously, and every report received will be assessed and, where necessary, an appropriate investigation will be undertaken. The confidentiality of reported violations will be maintained where possible, consistent with the need to conduct an adequate review and subject to applicable law.

Reports should in the first instance be made to the CEO or internal legal counsel, who will ensure that the information is properly handled and escalated as necessary. No retribution or retaliation will be taken against any person who has made a report based on the belief that a violation of this Policy has occurred.


The Company will impose discipline on individuals found to have breached this Policy, in a manner that is fair, consistent and that reflects the nature and facts of the violation. Anyone subject to this Policy who violates it may face disciplinary actions up to and including termination of his or her employment for cause and without notice. The violation of this Policy may also violate certain anti-bribery and anti-corruption laws. If the Company discovers a violation of any anti-bribery laws, it may refer the matter to the appropriate authorities, which could lead to penalties, fines or imprisonment and/or other liability.

This policy is approved by the Board of Directors on 1st January 2023.

This Code of Business Conduct and Ethics (this “Code”) applies to all directors, officers and employees (collectively the “Covered Persons”) of Pop Bio Sdn. Bhd. and all of its controlled subsidiaries (collectively the “Company”), unless such a controlled subsidiary has adopted its own Code of Business Conduct and Ethics that is consistent with the provisions of this Code.

This Code was laid out by the Board of Directors of the Company to ensure that the Covered Persons follow the Company’s commitment to the highest ethical standards and law. Adherence to this Code and to our other official policies is essential to maintaining and furthering our reputation for fair and ethical practices among our customers, shareholders, employees, communities and other stakeholders. Working with a strong sense of integrity is critical to maintaining trust and credibility.

This Code is meant to be a guide to appropriate conduct and describes the moral and ethical behavior that is expected from Covered Persons. As members of the Company, you should review the Code and policies that relate to your position and think about how they apply to you. If in doubt, please refer to this Code as to how you can obtain information, express concerns or report any suspected Code violations. If you have any questions or are unsure of what to do in a situation, you should seek guidance from your superior or manager. Alternatively, you may choose to call your respective Human Resource Department or the Chief Executive Officer.

Complying with and upholding these commitments is essential to the Company’s continued success. Employees who do not comply with this Code may be liable to disciplinary action including the termination of employment and/or referral to the appropriate authorities for criminal prosecution, and legal action in some cases.


1.1 Respect

All Covered Persons shall treat superiors, peers, subordinates and external stakeholders with respect, trust, honesty and dignity.

1.2 Equal Opportunity and No Discrimination

The Company provides equal opportunities to all and endeavors to ensure that employment-related decisions are based on relevant qualifications, merit, performance and other job-related factors and in compliance with all applicable laws and regulations. There shall be no discrimination based on gender, race, disability, nationality, religion, age or sexual orientation unless specific laws or regulations expressively provide for selection according to specific criteria.

1.3 Harassment and Violence

Any types of harassment and violence will not be tolerated. These actions or behaviors include derogatory comments based on gender, racial or ethnic characteristics, and unwelcomed sexual advances, spreading of malicious rumors or use of emails, voicemail and other forms of communication channels to transmit derogatory or discriminatory material. Please refer to the Company’s Workplace Harassment Policy for more information.

1.4 Criminal Activities

All Covered Persons must not engage or become involved in any behavior or activities that may be categorized as subversive or commit any wrongdoing, criminal or otherwise that is punishable under the laws of any country. If any Covered Person is found guilty by a court of law or found to be involved in subversive activities or commit a criminal offence, he/she will be dealt with in accordance with the Company’s relevant policies and procedures.

1.5 Environment, Occupational Safety and Health

The Company strives to provide a safe, secure and healthy working environment. Covered Persons must create and maintain a safe working environment to prevent workplace injuries by:

  • using all devices provided for the Covered Persons’ protection;
  • ensuring that protective devices are in good working condition;
  • reporting immediately unsafe equipment and tools, hazardous conditions and accidents to the respective Head of Department; and
  • complying with the Occupational Safety and Health laws and regulations of any country.

All Covered Persons are also responsible for the safety of fellow other Covered Persons and the general public and are encouraged to promptly report any breaches of environmental, safety and health laws at the workplace. In case of doubt, please seek clarification from the respective Head of Department.


2.1 General Guidance

A conflict of interest arises when a Covered Person have a personal interest that could be seen to have the potential to interfere with the effectiveness and objectivity in performing duties or exercising judgement on behalf of the Company. Conflicts of interest may not always be clear-cut. Any Covered Person who has any questions as to whether a conflict of interest exists should consult with such person’s supervisor or the Company’s Chief Executive Officer.

All Covered Persons must adhere to a high standard of business ethics and is expected to make decisions and take actions based on the best interests of the Company, as a whole, and not based on private relationships or benefits. In the event of a violation of the conflicts of interest law, a Covered Person may, under applicable state law, not be entitled to any indemnification payments by the Company. Further, insurance coverage for directors and officers may not be applicable due to a traditional exception with respect to any conduct in connection with a conflict of interest.

If you find yourself in a situation of conflict whether actual or potential, speak to your Head of Department, whom will escalate the same to the Chief Executive Officer, so that it could be managed properly.

2.2 Corporate Opportunities

Covered Persons are prohibited from: (a) taking for themselves personally opportunities that are discovered through the use of corporate property, information or position; (b) using Company property, information or position for personal gain; and (c) competing with the Company. Covered Persons owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

2.3 Dealing with Suppliers, Customers, Agents, Competitors

Every Covered Persons must ensure that their personal business dealings with suppliers, customers and agents are on an arms-length basis e.g. purchases which are on no more favorable terms than those offered to the public.
Any Covered Persons or their family members must not have:

  • Any financial interest in a supplier, customer, agent or competitor of the Company; and
  • Any business dealings or contractual arrangements with the Company. This excludes staff purchases for personal consumption, or purchases which are on no more favorable terms than those offered to the public.

2.4 Gifts, Benefits or Entertainment

As an employee of the Company, a Covered Person shall not be influenced by receiving favors nor shall they try to improperly influence others by providing favors. Employees shall not accept gifts, benefits or entertainment from a third party containing excessive value that would constitute a violation of laws or that could affect, or appear to affect, the professional judgement or create the impression of improperly influencing the respective business relationship. It can be viewed damaging to both the employee’s personal business reputation and that of the Company’s.

Please refer to the Company’s Anti-Bribery and Anti-Corruption Policy for more information.


3.1 Appropriate Use of Company Assets and Equipment

All employees are responsible to protect the Company’s assets. Employees should help to safeguard our Company assets and immediately report any suspected theft, damage, misuse, fraud, embezzlement or improper usage.

3.2 Managing Documents

The Company’s documents and records are meant for business purposes and requirements, compliance with legal, tax, accounting and regulatory laws. A Covered Person must control and maintain such records so that they are accurate, up-to-date, legible, readily identifiable and retrievable. Please consult your Head of Department for guidance if you are uncertain as to how you should manage the Company’s documents.

3.3 Intellectual Property and Information

A Covered Person may obtain confidential information not generally available or known to the public or the market in the course of its duties.

The Company values and protects all proprietary and confidential information. Hence, the Covered Person must not communicate or disclose this information in any manner to competitors, customers, persons engaged in any aspect of the securities industry, members of trade associations or other third parties unless such communication or disclosure is authorized by the Company. The obligation to preserve confidential information continues even after the Covered Person employment with us has ceased.

Confidential information is information of a non-public nature acquired and/or developed by the Company (in the course of its ordinary course of business or otherwise) and may include, without limitation to, data and technical know-how, patents, trademarks, business plan and budget, product design, customer list and information, information on current and future projects and work processes, financial information or other data that might be useful or helpful to competitors, or harmful to the Company or its customers or suppliers and etc.

3.4 Personal Data Protection

The Company respects the privacy and confidentiality of its employees, directors, counterparties, business partners and customers’ personal data. Personal data should be kept private and protected, unless access is granted for legitimate business purposes. If any Covered Person have access to such data, the Covered Person are required to comply with the applicable laws, such as Personal Data Protection Act, and also the Company’s policies. Appropriate measures must be taken if the Covered Person is dealing with personal data in terms of collection, processing, disclosure, security, storage and retention.

Please refer to the Company’s Personal Data Protection Policy for more information.


Money laundering is a process by which persons or groups try to conceal the proceeds of illegal activities or try to make the sources of their illegal funds look legitimate.

The Covered Persons should always ensure that they are conducting business with reputable customers, for legitimate business purposes and with legitimate funds. The Covered Persons need to be mindful of the risk of the Company’s business being used for money laundering activities and if they suspect money laundering activities, they should report it to such person’s Head of Department, the Chief Executive Officer or the Board.


The Company, through the Board, is responsible for applying this Code to specific situations in which questions may arise and has the authority to interpret this Code in any particular situation. This Code is not intended to provide a comprehensive guideline for Covered Persons in relation to their business activities with the Company.

The Company will take all action it considers appropriate to investigate any breach of the Code reported to it. All Covered Persons, directors and employees are required to cooperate fully with any such investigation and to provide truthful and accurate information. If the Company determines that a breach has occurred, it will take or authorize disciplinary or preventative action as it deems appropriate, after consultation with the Company’s counsel if warranted, up to and including termination of employment. Where appropriate, the Company will not limit itself to disciplinary action but may pursue legal action against the offending Covered Person involved. In some cases, the Company may have a legal or ethical obligation to call violations to the attention of appropriate enforcement authorities.

The Company reserves the right to amend this policy and guidelines at any time in its sole discretion.

This policy is approved by the Board of Directors on 1st January 2023.

This Workplace Harassment Policy (this “Policy”) applies to the directors, officers and employees (collectively the “employees”) of Pop Bio Sdn. Bhd. and all of its subsidiaries (collectively the “Company”) worldwide, unless such subsidiary has adopted its own Workplace Harassment Policy that is consistent with the provisions of this Policy.

This Policy reflects the commitment of the Company to provide a safe, healthy and harassment-free work environment for all employees. Through enforcement of this Policy and by communicating to employees, the Company will seek to prevent, correct and discipline behavior that violates this Policy in line with the applicable laws and regulations in Malaysia.


Harassment means any verbal, written or physical conduct that is known or ought reasonably to have been known to be unwelcomed, inappropriate or otherwise offensive to a person, and that such conduct demeans, humiliates, threatens him/her or otherwise violates his/her dignity. Harassment can take many forms such as words, signs, offensive jokes, cartoons, pictures, statements, pranks, intimidation, physical assaults or contacts, direct insults, bullying, victimization, offensive discussions, gestures, spiteful gossip and many more whether online or physical and has the effect of creating an intimidating, hostile or offensive workplace and interfering with the performance of an employee’s functions, duties and responsibilities; or affecting employment opportunities or compensation of an employee.

Examples of situation where harassment occurs (non-exhaustive) are:

  • Derogatory or condescending remarks, slurs, epithets or language or teasing regarding a person’s heritage, religion, or beliefs (verbal or written).
  • Unacceptable, annoying or unwanted nicknames or negative stereotyping.
  • Isolation or exclusion of a person from others.
  • Outbursts of anger and destruction of property.
  • Spreading malicious rumours to discredit someone.
  • Bullying and victimization, for example, unreasonable and persistent criticism or humiliation, unreasonable distribution of work and responsibilities.
  • Sabotaging or destructively interfering in the work of others.
  • Inappropriate inquiries or comments about a person’s religious or cultural norms, family background, source of income or lifestyle.
  • Retaliation.


Sexual Harassment is defined in the Code of Practice on the Prevention and Eradication of the Sexual Harassment in the Workplace issued by the Ministry of Human Resources, Malaysia in August 1999 and shall mean:

“Any unwanted conduct of a sexual nature having the effect of verbal, non-verbal, visual, psychological or physical harassment:

  • that might, on reasonable grounds, be perceived by the recipient as placing a condition of a sexual nature on her/his employment; or
  • that might, on reasonable grounds, be perceived by the recipient as an offence or humiliation, or a threat to his/her well-being, but has no direct link to her/his employment.”

It is essential to emphasize that sexual harassment refers to sexual conduct which is unwanted and unwelcome to the recipient, and it is also a sexual conduct which is imposed on and unsolicited or unreciprocated by the recipient.
Examples of situation where sexual harassment occurs (non-exhaustive) are:

  • Verbal
    offensive or suggestive remarks, comments, jokes, jesting, kidding, sounds, inappropriate inquiries or comments about a person’s sex life
  • Non-Verbal / Gesture
    leering or ogling with suggestive overtones, licking lips or holding or eating food provocatively, hand signal or sign language denoting sexual activity, persistent flirting
  • Visual
    showing pornographic materials, drawing sex-based sketches or writing sex-based letters, sexual exposure
  • Psychological
    repeated unwanted social invitations, relentless proposals for dates or physical intimacy
  • Physical
    inappropriate touching, patting, pinching, stroking, brushing up against the body, hugging, kissing, fondling, sexual assault

Sexual harassment is considered a criminal offence under the laws of Malaysia, including the following:

(a) Penal Code, Act 574

– Section 292 – distribution or public exhibition of obscene objects or documents

– Section 294 – doing any obscene act or singing, reciting or otherwise uttering obscene songs, ballads or words in public

– Section 354 – assault or use of criminal force to a person with intent to outrage modesty

– Section 376 – rape

– Section 377D – outrages on decency

– Section 509 – word or gesture intended to insult the modesty of a person

(b) Communications and Multimedia Act 1998, Act 588

– Section 233 – improper use of network facilities

(c) Film Censorship Act 2002, Act 620

– Section 5 – possessing, circulating, distributing or displaying obscene films

(d) Printing Press and Publications Act, 1984, Act 301

– Section 8 – possession and distribution of prohibited publications prejudicial to public morality


The Company does not tolerate unwarranted harassment of any kind towards its employees in the workplace.

This Policy aims to address and prevent antagonistic situations that violate the dignity of employees pertaining to single or repeated incidents of intimidation, humiliation, degradation, bullying, or other undesirable verbal, non-verbal, or physical conduct toward one person or a group of people of their race, ethnicity, national origin, disability, religion, age, gender, sexual orientation, gender identity and etc. The environment of the Company should be characterized by mutual trust and the absence of intimidation, oppression and exploitation. A breach of this Policy by any employee is considered a misconduct and may result in disciplinary measures being taken, including dismissal.


Any employee who has been harassed, or has witnessed or is affected by the harassment of others, especially in the workplace must take appropriate steps specified herein:

(a) immediately object and make clear to the harasser that their behavior is contrary to this Policy and that the harasser should immediately stop behaving in this manner;

(b) keep a written record of each incident of harassment, including the date, time, place, any evidence and available witnesses;

(c) talk to someone immediately after the incident and seek advice if you are unsure whether the event that occurred constitutes as harassment;

(d) make a formal complaint to the employee’s direct supervisor, Head of Department or directly to the Human Resources Department. Formal complaints made to the employee’s direct supervisor or Head of Department must be referred to the Human Resources Department at the earliest opportunity, and in any event within twenty-four (24) hours of the complaint being made.

Once the matter has been reported, the Company shall have a statutory responsibility to inquire into the complaints. Should the offending employee be found guilty with no reasonable defense, the Company have the discretion to take the following actions

(a) a written warning;

(b) a final written warning;

(c) suspension of employment (not more than 14 days within the scope of the Employment Act 1955);

(d) downgrading or demotion to a lower position;

(e) withholding increments or bonus;

(f) dismissal; or

(g) any other disciplinary action lesser than dismissal or downgrading which is appropriate.

No person will be adversely affected in employment as a result of bringing complaints, appearing as a witness in the investigation and/or serving as an investigator of an unlawful harassment complaint.

All direct supervisor, Head of Department or directly to the Human Resources Department shall handle harassment claims discretely to guard the integrity of the process and keep employees’ trust intact and prevent the complainant from facing any retaliation. Those who report misconduct or cooperate in the investigation should not be adversely affected either directly or indirectly. They should not feel as if they are being intimidated or punished by having their employment or working conditions put in jeopardy. Any manager, supervisor or other party found to have violated this aspect of the Policy will be subject to disciplinary action, including and up to dismissal.


The Company will diligently monitor these procedures to ensure that they meet the objectives of relevant legislations and remain effective, and, if necessary, implement changes subject to the approval of the Board of Directors.

This policy is approved by the Board of Directors on 1st January 2023.