Whistleblowing Policy

1. INTRODUCTION

Empire Premium Food Berhad (“Company”), together with all its subsidiary(ies) and joint venture company(ies) (collectively referred to as the “Group”) is committed to the highest standard of corporate governance and business integrity.

In recognising the abovementioned values, the Group provides an avenue for all employees of the Group and members of the public to raise their concerns or disclose any improper conduct within the Group and to take appropriate action to resolve them effectively.

2. OBJECTIVE

This Whistleblowing Policy (“Policy”) is formulated to enable the reporting of genuine concerns about any actual or possible improprieties at the earliest opportunity in good faith without the fear of retaliation so that appropriate actions can be taken to address or mitigate such concerns.

The intended objectives of this Policy are:

to encourage and develop a culture of openness, accountability, and integrity;
to provide avenues for the employees to raise genuine concerns or allegations through the appropriate channels upon discovery of any possible misconduct;
to ensure protection for an individual who reports the concerns or allegations in good faith in accordance with the procedures; and
to enable the management to be informed at an early stage about acts of misconduct.

3. DEFINITIONS

“Whistleblower” means any person (employee, director, shareholder, supplier, consultant, customer or member of the public) who makes a disclosure under this Policy.

“improper conduct” means any conduct which if proven, constitutes a disciplinary offence, a breach of law or unethical behaviour.

“good faith” means the whistleblower has a reasonable belief that the information disclosed is true and not made for personal gain or with malicious intent.

4. SCOPE AND APPLICABILITY

This Policy applies to the Group.

All directors and employees of the Group working at all levels and grades, shareholders, and any third parties associated with the Group, which may include but are not limited to customers, suppliers, contractors, agents, consultants, outsourced personnel, distributors, advisers, government and public bodies including their advisers, representatives, and officials are encouraged to report or disclose through established channels, concerns about any violations of the Group’s Code of Ethics and Conduct of the Group, the Anti-Bribery and Corruption Policy and any wrongdoings, including, but not limited to the following:-

fraud or dishonesty;
breaches of policies, procedures and applicable laws and regulations;
bribery or corruption or blackmail;
abuse of power;
conflict of interest;
criminal breach of trust;
sexual harassment;
criminal offences;
concealment of any, or a combination, of the above.

This Policy does not apply to grievances concerning an employee’s terms of employment or other employment-related concerns or complaints, which will be addressed through the Group’s human resources or management channels. This Policy also applies to external parties and the protection afforded under this Policy extends to all whistleblowers, whether internal or external.

5. ACTING IN GOOD FAITH

The Group expects all parties to act in good faith and have a reasonable belief that the information and any allegations in it are sustainably true and not acting for personal gain. Any anonymous whistleblower will not be entertained. However, the Group reserves its right to investigate any anonymous disclosure. If allegations are proven to be malicious, parties responsible may be subject to appropriate action, up to and including legal action, where applicable.

6. CONFIDENTIALITY

7. PROTECTION

The Group assures the whistleblower who raises issues of concern that he/she will be protected from interference with his/her lawful employment or livelihood, including discrimination, discharge, demotion, suspension, disadvantage, termination, or adverse treatment in relation to his/her employment, career, profession, trade or business or the taking of disciplinary action as a result of his/her reporting, provided the report is made in good faith and without malice. Any party that retaliates, including harassment and victimisation, against a whistleblower who has reported allegations in good faith may be subject to appropriate action, up to and including legal action, where applicable.

Any employee, officer or external party who retaliates, obstructs or attempts to interfere with a whistleblowing report or investigation shall be subject to disciplinary or legal action.

8. REVOCATION OF POLICY

The protection stated above shall be revoked by the Group if:

the whistleblower himself/herself has participated in improper conduct, wrongdoings, corruption, fraud and/or abuse;
the whistleblower made his/her disclosure without good faith;
the disclosure was frivolous or vexatious; or
the disclosure was made with the intention or motive to avoid dismissal or other disciplinary action against the whistleblower himself/herself.

9. ACTION

The protection stated above shall be revoked by the Group if:

The immediate superior /Chairperson/Chief Executive Officer (“CEO”)/Executive Director(s) (“ED”) of the Company, as the case may be, who receives the complaint shall maintain all complaints received, tracking their receipt, investigation, and resolution.
Each report shall be screened to assess its reliability and whether there is sufficient information to warrant an investigation.
All reports will be investigated promptly by the person receiving the report or disclosure. If required, assistance from other resources within the Group can be sought.
Upon completion of the investigation, an appropriate course of action will be recommended to the Audit and Risk Management Committee of the Company (“ARMC”) for their deliberation.
The decision taken by the ARMC will be implemented immediately. Where possible, steps will also be implemented to prevent similar situations from arising.
The ARMC shall then update the board of directors of the Company (“Board”) on the report of the status and outcome of the investigation and whether the effectiveness of the implementation of this Policy requires their attention and approval.

10. WHISTLEBLOWING REQUIREMENTS

The reports should be submitted together with the following information:-

details of the whistleblower (strongly encouraged, even though whistleblower may choose to remain anonymous);
type of activity/conduct;
the reason for the concerns;
details of suspected personnel involved;
details of the incident (including date, time and location of incident); and
any supporting/documentary of all factual evidence.

11. REVERTING TO THE WHISTLEBLOWER

The whistleblower will be informed on the progress and status of the investigation, however, the Group reserves the right not to inform the whistleblower of the precise action plan and/or the outcome of the investigation as this may infringe a duty of confidentiality owed to someone else.

12. WHISTLEBLOWING CHANNEL

The established channels for whistleblowing reporting are as follows:

Any concern should be raised with the immediate superior. If for any reason, it is believed that this is not possible or appropriate, then the concern should be reported to the Chairperson/CEO/ED of the Company. The channel of reporting is as follows:

By Mail:

Strictly Confidential

Empire Premium Food Berhad No. 5, 5th Floor, Block B, IOI Boulevard, Jalan Kenari 5, Bandar Puchong Jaya, 47170 Puchong, Selangor

Attention: The Chairperson/CEO/ED

Or

By Email:

whistleblower@empirepremiumfood.com
If for any reason, it is believed that reporting to the immediate superior /Chairperson/CEO/ED is a concern or not possible or appropriate, then the concern should be reported to the Chairperson of ARMC. The channel of reporting to the ARMC Chairperson is as follows:

By Mail:

Strictly Confidential

Empire Premium Food Berhad No. 5, 5th Floor, Block B, IOI Boulevard, Jalan Kenari 5, Bandar Puchong Jaya, 47170 Puchong, Selangor

Attention: The Audit and Risk Management Committee Chairperson

Or

By Email:

whistleblower@empirepremiumfood.com

13. REVIEW OF THE POLICY

This Policy will be reviewed at least once every three (3) years to ensure its effectiveness, and consistency with the governing legislation, the Board’s objectives, responsibilities and standards of corporate governance and regulatory requirements, or more frequently should there be material changes to the said legislation and regulations or circumstance of the business, if any.

14. BOARD APPROVAL

This Policy (Version No. 1) was reviewed and approved by the Board on 22 September 2025. Any amendment(s) to this Policy shall be approved by the Board from time to time, when necessary.