1. Purpose

AEON Bank (M) Berhad’s ("AEON Bank" or “the Bank”) Whistleblowing Policy has been designed to encourage the prompt reporting of actual or suspected illegal, unethical, or inappropriate behavior or practices, without fear of retribution. This policy outlines a clear process for reporting such concerns so that appropriate action may be taken. The goal of the Whistleblowing Policy is to protect and enhance AEON Bank’s reputation and integrity, ensuring that all stakeholders continue to have trust and confidence in our institution.

The AEON Bank Board of Directors is committed to maintaining a framework that fosters a culture of openness, supporting and encouraging the reporting of concerns through whistleblowing.

2. Scope

The Whistleblowing Policy applies to all members of the Board, Shariah Committee, Senior Management, and employees of AEON Bank, whether permanent, temporary, or contracted. AEON Bank also encourages its customers, as well as third parties who have business dealings with the bank, perform work or services on its behalf, or are otherwise associated with AEON Bank, to report any concerns about improper conduct that may have occurred within the Bank.

3. Whistleblowing: Raising a concern

Who May Raise a Concern

The following individuals may report genuine concerns about misconduct through AEON Bank’s whistleblowing channel:

(a) Any employee or member of the Board of Directors of AEON Bank, including former, temporary, or contracted employees.

(b) Any third party engaged in business dealings with AEON Bank, performing work or services on behalf of AEON Bank, or otherwise associated with the bank.

AEON Bank’s Reporting Channels

Concerns may be reported under strict confidence via online submission of the Whistleblowing Form to whistleblowing@aeonbank.com.my. Concerns should be raised in written format and can be done via the Whistleblowing Form.

Sufficient details as follow should be provided:

(a) Name of the individual raising the Concern including contact particulars such as contact number and residential address;

(b) Details of the Concern including the nature, parties involved, time, date, and location of the incident;

(c) Names of possible victims and person(s) who are involved;

(d) Potential financial or non-financial damage known;

(e) Names of possible witnesses to the incident (if any); and

(f) Supporting evidence (if any).

Whistleblowers should provide their full name and contact details, to facilitate AEON Bank to clarify or obtain further information for purposes of further investigation into the Improper Conduct.

Whistleblowers may opt for anonymity, however, AEON Bank does not encourage Concerns to be raised anonymously, given the limitations for anonymous claims. AEON Bank may not be able to commence investigation or investigations may be impeded if there is insufficient information.

What You Should or Can Raise as a Concern

Concerns to be raised should be genuine concerns and may include any of the following misconduct involving AEON Bank and/or that adversely impact AEON Bank and is not limited to the following:

a. Fraud, theft and embezzlement;

b. Bullying and harassment;

c. Corruption, bribery or blackmail;

d. Illegal activities, money laundering or criminal offences;

e. Insider Trading¹;

f. Conflict of Interest²;

g. Unethical sales practices;

h. Failure to comply with a legal or regulatory obligation;

i. Breach of policies and / or procedure; and

j. Miscarriage of justice;

k. Misuse of AEON Bank’s fund or property;

l. Misuse of AEON Bank’s information;

m. Endangerment of an individual’s health and safety;

n. Abuse of authority; and

o. Concealment or abetment of any of the above.

The Whistleblowing Policy does not cover any of the following:

a. Matters which are trivial, malicious or frivolous or are motivated by individual interest;

b. Complaints by AEON Bank’s customers or business associates of AEON Bank;

c. Enquiries on any of AEON Bank’s products and/or services.

d. Matters covered under Disciplinary Guidelines & Procedures; and

e. Matters pending resolution from any internal proceedings or authority or court or

similar proceedings.

¹ Insider Trading refers to the acquisition or disposal of AEON Bank’s related company shares by its
company executives, directors and major shareholders including their friends, and relatives based on the information obtained via access to material nonpublic information about the Bank for profit gains.


² A conflict of Interest occurs when an AEON Bank’s employee’s or a third party’s own personal interests
i.e. family, friendships, financial, or social factors, compromises his or her own judgment, decisions, or
actions in carrying out the duties to AEON Bank.

When You Should Raise a Concern

a. When an actual or suspected Concern is reasonably believed to have occurred, or is currently occurring or will be occurring, there are grounds for disclosures to be made in good faith.

b. In principle, raising a Concern should be done at the earliest possible opportunity.

c. Whistleblowers must understand that any delay in raising Concerns equates to a delay in the said Concern being addressed. This may also be detrimental to the investigation process.

d. For clarity, the individual raising the Concern is not required to procure material evidence to prove the factuality of the Concerns.

4. Rights and Responsibilities of The Whistleblower & AEON Bank

The Whistleblower

A Whistleblower has the right to confidentiality under the Whistleblowing Policy. Whistleblowers may opt for anonymity should they deem it necessary before they feel comfortable enough to raise a Concern.

However, AEON Bank does not encourage anonymous Concerns raised, as investigation may not be able to commence or it may be impeded if the Investigator is unable to seek clarification or further information from the Whistleblower.

Whistleblowers have the responsibility to:

a. Raise Concerns in good faith. ‘Good faith’ is when an individual honestly believes with sincere intentions, that the Concern raised is true; and

b. Provide all information when raising a Concern and thereafter to avail themselves to the Investigator.

AEON Bank has the responsibility to ensure the following:

a. That all Concerns raised by Whistleblowers shall be treated fairly and properly and in strict confidence;

b. That Whistleblowers shall retain anonymity unless they agree to otherwise or if disclosure is required by regulators or by law;

c. That the confidentiality of Whistleblowers shall be protected per the Whistleblowing Policy before, during and after an investigation;

d. That no Whistleblower or any party who provides information or assistance, shall be at risk of suffering some form of Retribution or Retaliation, even if the Whistleblower is mistaken;

e. That appropriate resources shall be made available to address Concerns raised by Whistleblowers;

f. That basic rights of Employees and/or Directors of AEON Bank implicated by any Whistleblower shall be respected; and

g. That action shall be taken against any breaches of the Whistleblowing Policy including but not limited to any form of Retaliation against Whistleblowers or breaches of confidentiality.

AEON Bank has the right to the following:

a.  Take any requisite action against a Whistleblower who raises a Concern which he or she knows is untrue and primarily done with malice; and

b. Take any requisite action against any party:

(i) Found guilty following an investigation; and

(ii) Destroying, concealing or falsifying records to impede, obstruct, or influence an investigation.

AEON Bank takes Whistleblower protection seriously as Whistleblowers are recognised as key stakeholders towards assisting AEON Bank in achieving the objectives of the Whistleblowing Policy. As such, on a case-to-case basis, AEON Bank shall consider multiple avenues within its ability to provide additional means of protection or safety to the Whistleblower, if necessary. These may include, for example, the provision of physical security, interim accommodation arrangements or restitution etc all of which are subject to approval of the BOD.

Consequences of breaches

Requisite action, not limited to those in accordance with AEON Bank’s Consequence Management Guideline, criminal prosecution and/or civil action, shall be taken against parties who breach the Whistleblowing Policy.

Similarly, Whistleblowers shall be subject to requisite action and may lose their rights and protection under the Whistleblowing Policy, if they:

a. Did not act in good faith in raising a Concern; or

b. Did not observe the confidentiality requirements under the Whistleblowing Policy.

Important Note: In principle, no Whistleblower shall be afforded the right to automatic immunity from any requisite action if they are subsequently implicated in the same Concern reported. This also applies to any party who provides information or assistance pursuant to the Whistleblowing Policy.

5. Confidentiality

All information received will be treated with strictest confidence. Investigation results shall not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of individuals suspected but subsequently found innocent of wrongful conduct and to protect AEON Bank from potential civil or criminal liability.

6. OTHER AVENUES FOR WHISTLEBLOWING

Individuals are encouraged to raise Concerns under the Whistleblowing Policy before considering approaching regulators and law enforcement agencies (e.g. BNM, MACC, the Royal Malaysia Police, Labour Department etc) first. For clarity, this is to permit issues raised by Whistleblowers to be addressed immediately. Nonetheless, apart from via Whistleblowing Policy, individuals can report Concerns directly to regulators or law enforcement agencies under the Whistleblower Protection Act 2010.