Speak-Up & Whistleblowing Policy

1. Purpose

TAPiO Management Advisory Sdn. Bhd. encourages concerns about suspected wrongdoing to be raised early and responsibly. The purpose of this Policy is to provide a trusted route for raising concerns, to support fair assessment and investigation, and to protect people who speak up in good faith from retaliation.

This internal Policy is separate from statutory whistleblower protections. It does not limit any person’s right to contact a competent authority, seek legal advice or exercise rights available under applicable law.

2. Who may speak up

This Policy is available to directors, employees, interns, consultants, contractors and other persons working for or with TAPiO. Clients, suppliers, business partners, event participants and other external stakeholders may also use the reporting channel for serious concerns connected with TAPiO or persons acting on its behalf.

3. What should be reported

Examples include suspected:

• bribery, corruption, kickbacks, fraud, theft or falsification of records;
• serious conflicts of interest or abuse of position;
• money laundering, sanctions evasion or other serious financial misconduct;
• harassment, sexual harassment, exploitation, abuse, safeguarding concerns or serious workplace misconduct;
• material breaches of privacy, confidentiality, information security or data-protection obligations;
• serious violations of law, contract, professional standards or TAPiO policy;
• retaliation against a person who raised a concern;
• deliberate concealment or destruction of evidence relating to suspected wrongdoing; or
• other conduct that could seriously harm people, clients, TAPiO, public trust or the integrity of an engagement.

You do not need proof before speaking up. A reasonable, good-faith concern is sufficient.

4. What this process is not for

Routine service complaints, invoicing questions, ordinary disagreements or personal employment grievances that do not involve suspected wrongdoing should normally be handled through the relevant business or employment process. If a matter contains both a grievance and a misconduct concern, TAPiO may handle the issues through more than one process.

5. Reporting channels

Concerns should be made through a channel appropriate to the circumstances:

1. to your direct manager or another senior manager, if you are comfortable doing so;
2. to TAPiO’s designated confidential Speak-Up channel; or
3. if the concern involves the person who would normally receive the report, to the Chairperson or another person designated by TAPiO’s governing body.

If a report concerns the Managing Director or the normal recipient of the Speak-Up channel, the reporter should clearly mark it “For Chairperson Only”. TAPiO should maintain an access arrangement that enables such reports to bypass the person concerned.

6. Anonymous reports

TAPiO will consider anonymous reports where sufficient information is provided. However, anonymity may limit our ability to clarify facts, assess credibility, provide feedback or investigate fully. Reporters who identify themselves may request that their identity be kept confidential as far as reasonably possible.

7. Information to provide

A useful report should, where known, describe what happened, who was involved, when and where it occurred, why it is concerning, whether it is ongoing, and what records or witnesses may exist. Do not obtain evidence unlawfully or put yourself or another person at risk to gather information.

8. Confidentiality and non-retaliation

TAPiO will handle reports on a need-to-know basis and will take reasonable steps to protect the identity of a reporter and other affected persons, subject to fair-process requirements, legal obligations and the practical needs of an investigation.

Retaliation is prohibited against a person who raises a concern in good faith, seeks advice about reporting, assists an investigation or refuses to participate in suspected wrongdoing. Retaliation may include dismissal, demotion, threats, harassment, discrimination, adverse assignment, intimidation or other detrimental treatment connected with speaking up.

Anyone who believes they are experiencing retaliation should report it promptly through the Speak-Up channel.

9. Assessment and investigation

Reports will be assessed to determine appropriate next steps. Depending on seriousness, independence and expertise required, TAPiO may appoint an internal reviewer or an external legal, forensic, HR, data-protection or other specialist.

Investigations should be objective, proportionate and conducted by persons without a material conflict of interest. Relevant evidence should be preserved. Persons affected by allegations should be treated fairly and given an appropriate opportunity to respond where required.

Where the allegation concerns senior leadership, the matter should be overseen by a person or body sufficiently independent of the subject of the allegation.

10. Outcomes and feedback

Where appropriate, TAPiO may take remedial, disciplinary, contractual, control-improvement or reporting action. The reporter may receive confirmation that the matter has been reviewed or closed, but privacy, legal privilege, confidentiality and employment obligations may limit the detail that can be provided.

11. External reporting and statutory rights

Nothing in this Policy prevents a person from making a lawful disclosure to the Malaysian Anti-Corruption Commission, police, another competent enforcement agency, regulator, court or other authority, or from seeking independent legal advice.

Protection under Malaysia’s Whistleblower Protection Act 2010 and other statutory regimes is governed by those laws and the circumstances of the disclosure. TAPiO does not represent that an internal report automatically creates statutory whistleblower status or immunity.

12. Records and data protection

Speak-Up records must be stored securely with access restricted to persons who need them for assessment, investigation, governance or legal purposes. Personal data is processed in accordance with the Privacy & Data Protection Notice and any additional confidentiality requirements applicable to an investigation.

13. Knowingly false reports

A report made in good faith is protected even if it is not substantiated. Deliberately fabricating an allegation, falsifying evidence or knowingly making a malicious false report is a serious matter and may result in appropriate action. A concern is not malicious merely because an investigation reaches a different conclusion.

14. Responsibilities

Managers must take concerns seriously, preserve confidentiality and escalate matters appropriately rather than investigating informally where independence may be compromised. TAPiO’s leadership is responsible for maintaining a credible reporting route, preventing retaliation and ensuring serious matters receive appropriate oversight.

15. Review

TAPiO will review this Policy and the effectiveness of its reporting arrangements periodically and after significant cases or legal changes. Lessons from substantiated concerns should be used to strengthen controls where appropriate.