1. OVERVIEW

This Whistleblowing Policy (“Policy”) is a framework for reporting of concerns about irregularities within the Ingenious Works International Sdn. Bhd. (“ING” or “The Company”) operations and to avert possible risks of loss or reputation damage to the Company. It encourages and facilitates Employee(s) (“The Whistleblower”) to disclose genuine concerns of Improper Conduct within the Company, whilst protecting the person making such disclosures from any reprisal action. This Policy provides a safe and confidential channel for employees, contractors, suppliers, and other stakeholders (hereafter referred to as ‘associates’) to report concerns regarding misconduct or unethical practices within the Group. By fostering an open environment, we encourage whistleblowing in good faith and ensure that reports are dealt with fairly, promptly, and without fear of retaliation.

2. OBJECTIVES

The Policy’s main objectives are:

(i) To encourage and guide Employees and members of the public to communicate and disclose any Improper Conduct within the Company to the appropriate party within the Company in accordance with this Whistleblowing Policy; and

(ii) To clarify the protection accorded to Employees and members of the public who report allegations of any Improper Conduct;

(iii) To ensure disclosures of improper Conduct is managed in an appropriate and timely manner.

3. SCOPE

The Policy applies to any Improper Conduct by any Employee of the Company that affects others, such as other Employees, consultants, vendors, contractors, outside agencies or Employees of such agencies, and/or any other parties which have a business relationship with the Company.

4. TYPES OF REPORTABLE CONCERNS

Individuals may report any concerns or suspicions regarding the following:

(a) Fraud or financial misconduct (Any action deliberately designed to cause loss to the Company or to obtain any unauthorized benefit, whether directly or indirectly)

(b) Bribery or corruption (including improper gifts, favors, or benefits)

(c) Violation of laws or regulations (e.g., health and safety, environmental standards, or labor laws)

(d) Breaches of Company policies (e.g., Anti-Bribery and Corruption Policy)

(e) Discrimination, harassment or abuse

(f) Misuse of Company’s resources or information

(g) Unsafe working conditions

(h) Conflict of interest

(i) Intellectual Property (IP) Theft (e.g., unauthorized use of company IP or proprietary information, such as patents, trademarks, and trade secrets.)

We believe in addressing workplace concerns openly and efficiently. Therefore, employees are generally encouraged to first report any issues or potential violations through the appropriate formal reporting channels, allowing for direct communication and resolution.

However, we recognize that in certain circumstances, an employee may fear reprisal or prefer to remain anonymous, particularly when reporting serious unethical conduct. In such cases, this whistleblowing channel is available to provide a safe and confidential means of reporting.

Although the Whistleblower is not expected to prove beyond reasonable doubt the truth of the disclosure, the Whistleblower shall need to demonstrate that there are reasonable grounds for his / her concern and provide sufficient information for the Company to take appropriate steps. The Whistleblower shall not attempt to personally conduct any investigation, interview or interrogation related to the matter being disclosed.

5. REPORTING CHANNELS

The Company provides the following channels for reporting concerns:

(i) Email: ingenious.mgmt@gmail.com

(ii) Submission of Whistleblower Form

Individuals are encouraged to make use of the digital “Whistleblower Form” as per following,

Reports may be made anonymously, though individuals are encouraged to provide contact details to enable the Management to obtain further information required for investigation or clarification. We aim to handle all reports confidentially and with utmost sensitivity.

6. WHISTLEBLOWER PROTECTION

We are committed to protect whistleblowers (Employee, Vendors, Public, etc.) from:-

• Reprisal and/or Retaliation: There will be no adverse action, such as termination, demotion, or harassment, taken against any individual who reports concerns in good faith.

• Confidentiality: The identity of whistleblowers will be kept confidential unless the whistleblower consents otherwise or unless disclosure is required by law.

• Non-retribution: The Company will not tolerate any form of retaliation or discrimination against whistleblowers.

Retaliation against any whistleblower will result in disciplinary action, including possible termination.

The Company reserves the right to revoke the whistleblower protection accorded under this Policy if the whistleblower has, or is found to have:

(a) made a whistleblowing report not in good faith and/or made with malicious intent, ulterior motive or for personal gain;

(b) participated in the reported misconduct or complaint;

(c) made a disclosure not in accordance with the requirements of this Policy, including any disclosures that are deliberately false, dishonest, mischievous, malicious, frivolous or vexatious; or

(d) made the report solely or substantially to avoid dismissal or any other disciplinary action.

7. RESPONSIBILITIES

The Directors of the Company and Management Committee shall be responsible for the administration and compliance with this policy.

• Management: All management staff are responsible for fostering an environment that supports the policy and encourages the reporting of concerns. Management will act promptly to address any concerns raised by employees or other stakeholders.

• Employees and Stakeholders: Every individual covered by this policy has a responsibility to report any concerns they believe to be true and that may indicate unethical or illegal conduct.

8. INVESTIGATION PROCEDURES

Upon receipt of a report:

1. Acknowledge Receipt: The whistleblower will be acknowledged within 3 working days (If non anonymous)

2. Initial Assessment: The Management will assess the complaint report within 14 working days to establish whether the claim has merit or can be substantiated and if an investigation is warranted.

3. Investigation: If the report is substantiated, a detailed investigation will be carried out within 14 working days from the conclusion of the initial assessment. The whistleblower may be asked to provide further details or evidence. The Management will complete the detailed investigation within 60 working days or such other time deemed necessary.

4. Outcome: The findings of the investigation will be discussed with the ING’s Management, and/or Human Resources (HR) for next course of actions. Where necessary, action will be taken to address the issue, including disciplinary measures, legal actions, or reporting to the relevant regulatory bodies or authorities.

5. Quarterly Reports: On a quarterly basis, the Management shall prepare a summary report of the whistleblowing cases received and investigated and present it to the Management Committee for notation.

9. REPORTING TO AUTHORITIES

If a whistleblowing report involves violations of any law or regulation, the reporting shall be done by The Management. The Management will cooperate fully with the relevant authorities, including the Royal Malaysia Police (PDRM), Malaysian Anti- Corruption Commission (MACC), Securities Commission Malaysia (SC), or any other relevant authorities in the event of any investigations arising from such reporting.

10. RECORD KEEPING

All reports, investigations, and actions taken will be documented and securely stored for a minimum of 5 years, or a duration deemed necessary. Access to these records will be restricted to authorized personnel only.

11. COMMUNICATION AND AWARENESS

The Company will communicate this policy to all employees and stakeholders regularly. This policy is available on ING company website. Additionally, periodic training on ethical conduct, anti-corruption, and reporting channels will be provided.

12. POLICY REVIEW

This policy will be reviewed regularly, at least once in 3 years to ensure its effectiveness and compliance with applicable laws, regulations, and standards. Any amendments or updates to the policy will be communicated to employees and stakeholders.