\n This policy reflects KLCC (Holdings) Sdn. Bhd.’s overarching commitment to provide a safe and confidential channel for all employees, directors, the contingent workforce of KLCC Group of Companies and members of the public (“Whistleblowers”) to report concerns about any improper conduct without fear of retaliation.\n<\/p>\n\n
\n When you report a concern, you can expect that your report will be treated seriously, fairly and promptly.\n<\/p>\n\n
\n For information on the processing of your personal data in the whistleblowing channel, please refer to the Whistleblowing Privacy Notice.\n<\/p>\n\n
\n KLCC (Holdings) Sdn. Bhd. is committed to the highest standards of integrity, openness and accountability in the conduct of its businesses and operations. It aspires to conduct its affairs in an ethical, responsible and transparent manner. KLCC (Holdings) Sdn. Bhd. encourages the reporting in good faith about any improper conduct within KLCC (Holdings) Sdn. Bhd. as well as any non-compliance by a third party where this could affect KLCC (Holdings) Sdn. Bhd.\n<\/p>\n\n
\n This policy is designed to facilitate Whistleblowers to report any violations or potential violations (misconduct or criminal offence) through internal channel. Such misconduct or criminal offences include the following:\n<\/p>\n\n
\n All reports are to be made via the following secured and confidential channels in accordance with the procedures as provided under this policy, subject to the requirements of applicable laws:\n<\/p>\n\n
\n While KLCC (Holdings) Sdn. Bhd. encourages Whistleblowers to identify themselves to ensure the most efficient and comprehensive investigation and resolution of reports, Whistleblowers have the option to submit reports anonymously. KLCC (Holdings) Sdn. Bhd. takes the protection of confidentiality of identity very seriously and will take all reasonable steps to ensure confidentiality as best as possible. You will not be subject to retaliation from KLCC (Holdings) Sdn. Bhd. for any report of a suspected violation that is made in good faith and without malicious intent, and you have raised as a genuine concern, even if it later turns out to be factually incorrect. Please be aware, however, that knowingly providing false or misleading information will not be tolerated.\n<\/p>\n\n
\n KLCC (Holdings) Sdn. Bhd. strictly prohibits and will not tolerate any form of retaliation against any person who, in good faith and without malicious intent, has made a report or disclosure of violations or potential violations pursuant to this Policy.\n<\/p>\n\n
\n For the avoidance of any doubt, KLCC (Holdings) Sdn. Bhd. reserves all rights to inform competent authorities of any violations of the law.\n<\/p>\n\n
\n For further information, please refer to the KLCC (Holdings) Sdn. Bhd. Non-Retaliation Policy.\n<\/p>\n\n
\n This Policy applies to every employee, director and third party with business dealings with KLCC (Holdings) Sdn. Bhd. Joint venture companies in which KLCC (Holdings) Sdn. Bhd. is not a controlling stakeholder and associate companies of KLCC (Holdings) Sdn. Bhd. are encouraged to adopt this policy whilst our contractors, agents, outsourced workers and business associates are required to always act consistently with applicable parts of this Policy when dealing with, acting on behalf of, or in the name of KLCC (Holdings) Sdn. Bhd.\n<\/p>\n\n
\n KLCC (Holdings) Sdn. Bhd. reserves the right to amend this policy from time to time.\n<\/p>\n
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\n This policy reflects KLCC (Holdings) Sdn. Bhd.’s overarching commitment to upholding the highest standards of integrity and ethical behaviour throughout our business operations.\n<\/p>\n\n
\n Additionally, any appearance of bribery or corruption should be avoided to protect KLCC (Holdings) Sdn. Bhd.’s reputation.\n<\/p>\n\n
\n KLCC (Holdings) Sdn. Bhd. is committed to combating bribery and all forms of corruption and aims to uphold transparency and integrity throughout our business dealings, whether with governmental agencies, public sector or private enterprises.\n<\/p>\n\n
\n KLCC (Holdings) Sdn. Bhd. has a zero-tolerance approach to bribery and corruption. KLCC (Holdings) Sdn. Bhd. strictly prohibits all forms of bribery and corruption, including facilitation payments, kickbacks and political contributions. We have adopted a strict “No Gift” policy.\n<\/p>\n\n
\n Any request for a bribe or offer of a bribe shall be rejected. You shall not offer, promise, give, ask for or accept anything of value or any gratification, as a reward for any action in relation to KLCC (Holdings) Sdn. Bhd.’s business. You shall not authorise others to do so on your behalf.\n<\/p>\n\n
\n This policy is in line with the PETRONAS Code of Conduct and Business Ethics (CoBE) and is guided by other applicable internal policies, procedures and guidelines including the PETRONAS Anti-Bribery and Corruption Standard.\n<\/p>\n\n
\n This policy applies to every employee, director and third party working for or on behalf of KLCC (Holdings) Sdn. Bhd. Joint venture companies in which KLCC (Holdings) Sdn. Bhd. is not a controlling stakeholder and associate companies of KLCC (Holdings) Sdn. Bhd. are encouraged to adopt this policy or similar principles and standards.\n<\/p>\n\n
\n Any violation of applicable anti-bribery and corruption laws may result in administrative action, civil or criminal liabilities, impact business continuity, affect contractual obligations and cause significant reputational damage.\n<\/p>\n
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\n This policy reflects KLCC (Holdings) Sdn. Bhd.’s overarching commitment to upholding the highest standards of integrity, ethical behaviour, transparency and accountability by ensuring that employees, directors, the contingent workforce of KLCC Group of Companies and third parties with business dealings with KLCC (Holdings) Sdn. Bhd. can raise concerns without any fear of retaliation.\n<\/p>\n\n
\n KLCC (Holdings) Sdn. Bhd. strictly prohibits and will not tolerate any form of retaliation against any person who, in good faith and without malicious intent, has made a report or disclosure of violations or potential violations through the relevant reporting channels. Reports are considered made in good faith when the individual has reasonable grounds to believe that the information disclosed indicates a violation or potential violation, even if the concern is later proven to be unfounded.\n<\/p>\n\n
\n The types of retaliation prohibited by this policy include blatant acts such as dismissal, demotion, suspension, harassment or public attack, as well as more subtle acts of discrimination against a reporting individual or individuals investigating any misconduct or those cooperating in an investigation.\n<\/p>\n\n
\n Retaliation constitutes serious misconduct that may be subject to disciplinary action, including dismissal.\n<\/p>\n\n
\n For the avoidance of any doubt KLCC (Holdings) Sdn. Bhd. reserves all rights to inform competent authorities of any violation of the law.\n<\/p>\n\n
\n Subject to applicable laws, the protection is not applicable in the following circumstances, among others:\n<\/p>\n\n
\n Disciplinary or legal actions may still apply in such cases.\n<\/p>\n\n
\n Any individual who is being subject to retaliation contrary to this policy may submit a report through the designated reporting channels.\n<\/p>\n\n
\n All employees, directors and third parties working for or on behalf of KLCC (Holdings) Sdn. Bhd. shall adhere to this policy and ensure compliance with all applicable laws and regulations in their business dealings with KLCC (Holdings) Sdn. Bhd. Joint venture companies in which KLCC (Holdings) Sdn. Bhd. is not a controlling stakeholder and associate companies of KLCC (Holdings) Sdn. Bhd. are encouraged to adopt this policy or similar principles and standards.\n<\/p>\n\n
\n Any violation of applicable laws may result in administrative action, civil or criminal prosecution of KLCC (Holdings) Sdn. Bhd. and its employees, impact business continuity, have contractual implications, and cause significant reputational damage.\n<\/p>\n\n
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