mmc

30245-H

WHISTLEBLOWING POLICY




POLICY STATEMENT

MMC is committed to promote and maintaining high standards of transparency, accountability, ethics and integrity at the workplace in line with its Integrity, iNnovation, Teamwork, Excellence and Commitment ("INTEC") values. An accountable and transparent workplace provides a mechanism for employees to voice genuine concerns in a responsible and appropriate manner.



OBJECTIVE

This Policy is formulated to help employees and third parties report possible improprieties at the earliest opportunity so that concerns can be raised without fear of reprisal or detrimental action.



SCOPE

This Policy applies to all employees and third parties who has become aware of or genuinely suspects on a reasonable belief that an employee of the Company has engaged, is engaged or is preparing to engage in any Improper Conduct.



IMPROPER CONDUCT

Improper Conduct is any conduct which, if proved, constitutes a disciplinary action or a criminal offence. These include the following:



RAISING A CONCERN

A disclosure of Improper Conduct may be made orally or in writing (via a letter or electronic e-mail to mmcwbreport@gmail.com). When a disclosure is made orally, the person receiving the disclosure shall, as soon as it is practicable, reduce the same to writing. Any Improper Conduct that is discovered or genuinely suspected by the Whistleblower shall be reported immediately to the Chief Internal Auditor.



PROTECTION

The Whistleblower or persons connected to him/her shall be protected from any detrimental action as a direct consequence of the disclosure. Additionally, the Whistleblower's identity and such other confidential information shall not be disclosed save with the Whistleblower's consent or otherwise required by law. The protection conferred under this Policy is not affected notwithstanding that the disclosure of the improper conduct does not result in any disciplinary action on the person against whom the disclosure was made.



NOTIFICATION

The Whistleblower shall be informed of the result of any investigation and/or any action taken by the Company in respect of the disclosure in accordance with the Policy.




MMC reserves the right to amend this Policy from time to time.