1. BACKGROUND AND PURPOSE

SK Magic Retails Malaysia Sdn Bhd (“Company”) is committed to the values of transparency, integrity, impartiality and accountability in the conduct of its business and affairs and in its nature of work.

This Policy provides any persons acting in good faith to raise concerns and disclose actual or potential wrongdoings or misconduct in the Company. These wrongdoings or misconduct include but are not limited to:

1. violation of laws and regulations,
2. unethical behavior or breach of Company’s Code of Ethics,
3. giving, solicitation or acceptance of bribes,
4. acts that adversely affect the interests or values of the Company
5. unauthorized disclosure of Company information,
6. falsification of reports or documents,
7. fraud, theft, embezzlement or misuse of Company assets,
8. improper or undesirable personal behavior or misdeeds which seriously impacts our Company’s business or reputation,
9. sexual or other forms of harassment; and
10. attempts to cover any of the aforementioned.

2. PROCEDURES AND REPORTING

A whistleblower is encouraged to make a report of the wrongdoing when the whistleblower becomes aware and reasonably believes in good faith that a wrongdoing is likely to happen, is being committed or has been committed.

The whistleblower needs to demonstrate that the whistleblower has reasonable grounds for the concerns. However, the whistleblower is not expected to first obtain substantial evidence of proof beyond reasonable doubt when making a disclosure. If the whistleblower knows as a matter of fact that there are reasonable grounds of suspicion that a wrongdoing is going to take place, such genuine concerns is encouraged to be raised at an early stage.

A disclosure of a wrongdoing can be made via a report. The following particulars in the report:

• Details and description of the wrongdoing, including, its nature, the date, time, and place of its occurrence and the identity of the alleged person(s) involved. (A disclosure may be made even if whistleblower is not able to identify the identity of the person(s) involved)
• Any other particulars such as witnesses, if any; and or documentary evidence, if any.

3. INVESTIGATION

The Company shall conduct its own internal investigations comprising appropriate and suitably qualified personnel to investigate the concerns disclosed in the whistleblowing report in a fair and objective manner and to ascertain whether it is related to a Wrongdoing or excluded from the scope of this Policy. Thereafter, the qualified investigation personnel shall make general recommendations to the Managing Director and/or Board of Directors.

The Managing Director and/or Board of Directors has the authority to make the final decisions including, but not limited to the following:

• consideration under other internal procedures or disciplinary procedures including suspension, termination (if appropriate and applicable);
• suspending the alleged wrongdoer or any other implicated person to facilitate any fact finding;
• obtaining any other assistance (ie, legal advise or external auditors); and
• referral to the police or any other appropriate enforcement authority.

If the wrongdoing involves any of the Board of Directors, the recommendation shall also be made to the Board of Directors of SK Group Korea for decision.

In the event, the whistleblower is implicated or discovered to be or have been involved in any wrongdoing, the whistleblower may also be investigated.

4. CONFIDENTIALITY AND PROTECTION UNDER THE POLICY

The Company shall endeavour to keep the personal details provided by the Whistleblower confidential unless:-

• the whistleblower participated in the wrongdoing;
• the whistleblower expressly agrees otherwise, and provides his agreement in writing; or
• otherwise required by law for any purpose of proceedings.

5. NOTICE

Please take notice that this policy is not intended for employees to lodge employee grievances or appeal on disciplinary procedures. Employees can report employee grievances or lodge appeals on disciplinary procedures through the Company’s human resources department.

This Whistleblowing Policy may be updated or amended from time to time.