Effective Date: January 1, 2025
Last Updated: January 1, 2025

1. Introduction
1.1 Net Onboard Sdn Bhd is committed to maintaining the highest ethical standards, transparency, and integrity in all business operations.
1.2 This Whistleblower & Anti-Corruption Policy establishes:
– A secure and confidential mechanism for reporting unethical behavior, corruption, and legal violations.
– Net Onboard’s zero-tolerance stance on corruption, bribery, fraud, and misconduct.
1.3 This policy complies with:
– Malaysian Anti-Corruption Commission (MACC) Act 2009
– Whistleblower Protection Act 2010 (Malaysia)
– ISO 37001 Anti-Bribery Management System
1.4 This policy applies to:
– All employees, directors, executives, vendors, business partners, and stakeholders of Net Onboard.
– Any third party engaging in business with Net Onboard.

2. Whistleblower Protection & Reporting Channels
2.1 Who Can Report?
– Employees, contractors, vendors, customers, and any stakeholder who becomes aware of illegal, unethical, or fraudulent activities.
2.2 Types of Reportable Violations:
– Bribery & Corruption – Offering, accepting, or soliciting bribes.
– Fraud & Financial Misconduct – Falsifying records, money laundering, embezzlement.
– Conflict of Interest – Undisclosed relationships affecting business decisions.
– Harassment & Discrimination – Workplace harassment, unfair treatment, or abuse of power.
– Breach of Company Policies – Violations of Net Onboard’s Code of Conduct, ESG Policy, or Data Privacy Regulations.
2.3 How to Report?
– Email: [email protected]
– Anonymous Submission Form: Available on Net Onboard’s compliance webpage.
– Whistleblower Hotline: +60-126171688 (available 24/7).
2.4 Confidentiality & Whistleblower Protection:
– All reports are treated with strict confidentiality and will not be disclosed without consent.
– Whistleblowers are protected against retaliation, termination, or discrimination.

3. Investigation & Case Handling Process
3.1 Initial Assessment & Case Review:
– All reports will be reviewed by the Whistleblower Investigation Committee within 5 working days.
– If the report is valid, a formal investigation will be initiated.
3.2 Investigation & Evidence Gathering:
– Investigators will collect documentary, digital, and testimonial evidence.
– If necessary, external auditors or law enforcement authorities may be involved.
3.3 Resolution & Corrective Actions:
– If misconduct is confirmed, Net Onboard will take necessary disciplinary/legal action, which may include:
– Termination of employment or business contracts.
– Legal proceedings if the act violates Malaysian laws.
– Policy or procedural improvements to prevent recurrence.
3.4 Communication with the Whistleblower:
– A final update will be provided to the whistleblower within 30 working days, where applicable.

4. Anti-Corruption Policy & Zero-Tolerance for Bribery
4.1 Prohibited Conduct:
– Offering, giving, receiving, or soliciting bribes, kickbacks, or illegal commissions.
– Influencing business decisions through gifts, excessive entertainment, or personal favors.
– Engaging in fraudulent financial activities to gain competitive advantage.
4.2 Gifts & Hospitality Policy:
– Modest gifts and hospitality are allowed if they comply with:
– Local business practices and laws.
– Net Onboard’s Gift & Entertainment Policy.
– Gifts exceeding RM1000 must be disclosed and approved by senior management.
4.3 Third-Party & Vendor Compliance:
– All suppliers, vendors, and partners must sign Net Onboard’s Anti-Corruption Agreement.
– Any vendor engaging in corruption will be blacklisted and reported to authorities.

5. Compliance Training & Monitoring
5.1 Mandatory Anti-Corruption Training:
– All employees and vendors must complete anti-bribery and corruption training annually.
– Leadership and finance teams receive enhanced compliance training.
5.2 Regular Audits & Risk Assessments:
– Internal compliance audits are conducted to monitor financial transactions and contract awards.
– Risk assessments identify corruption vulnerabilities and improve governance measures.

6. Disciplinary Actions & Legal Consequences
6.1 Consequences of Policy Violation:
– Employees found guilty of corruption or bribery will be terminated immediately.
– Vendors or partners engaging in unethical practices will be banned from doing business with Net Onboard.
– Severe violations may result in legal action under the MACC Act 2009.
6.2 Regulatory Reporting to Authorities:
– If necessary, Net Onboard will report serious corruption cases to the MACC or relevant enforcement agencies.

7. Governing Law & Dispute Resolution
7.1 This policy is governed by Malaysian law, including the MACC Act 2009 and Whistleblower Protection Act 2010.
7.2 Any disputes will be resolved through mediation before proceeding to arbitration or litigation.

8. Amendments & Updates
8.1 Net Onboard reserves the right to update this Whistleblower & Anti-Corruption Policy at any time.
8.2 Employees, vendors, and stakeholders will be notified of material changes via email or internal communications.
For whistleblower reports, contact [email protected].