GOVERNANCE & POLICY

OUR COMMITMENT TO INTEGRITY

Our company is committed to maintaining high standards of integrity, transparency, and accountability in all areas of our business. We encourage employees, contractors, vendors, and other stakeholders to report any concerns related to unethical or illegal practices within our company. This Whistleblowing Policy outlines the process and protections in place for reporting such concerns confidentially and securely.

PURPOSE

The purpose of this policy is to provide a safe, confidential channel for reporting instances of misconduct, fraud, corruption, or any behavior that violates our company’s values, policies, or applicable laws. This policy ensures that concerns are addressed responsibly, fairly, and in a timely manner without fear of retaliation.

SCOPE

This policy applies to all employees, contractors, suppliers, clients, and other stakeholders. It covers, but is not limited to, the reporting of:

Financial fraud or mismanagement
Health and safety risks
Harassment or discrimination
Violations of company policies or procedures
Environmental harm or damage
Any form of unethical or illegal conduct

INVESTIGATION PROCESS

Upon receiving a report, our HR Team will conduct a preliminary assessment and may initiate a formal investigation. This process includes:

Acknowledging receipt of the report within 3 working days
Conducting an impartial, confidential investigation
Gathering relevant information and evidence
Taking corrective actions where necessary

PROTECTION AGAINST RETALIATION

We are committed to ensuring that whistleblowers are protected against any form of retaliation or unfair treatment. Any employee found to be retaliating against a whistleblower may face disciplinary action, up to and including termination.

CONFIDENTIALITY

All reports and investigations will be handled in strict confidence. Information will only be shared with those directly involved in the investigation process or as required by law.

FALSE REPORTING

While this policy encourages the reporting of genuine concerns, intentionally submitting false or malicious reports is strictly prohibited and may result in disciplinary action.

ACKNOWLEDGMENT

I acknowledge that I have read and understood the Whistleblowing Policy. I am aware of the procedures for reporting concerns, the protectoin against retaliation, and my responsibility to report unethical or illegal conduct in good faith.

REPORTING PROCEDURE

We encourage individuals to report concerns through the following confidential channels:

1.Email: wbc@geohan.com

Reports can be made anonymously; however, providing contact information can help us conduct a more thorough investigation.

CONTACT

For questions or further clarification about this policy, please contact HR Team at confidential@geohan.com.

Our company is committed to providing a safe, respectful, and inclusive workplace where all employees, clients, contractors, and partners feel valued and protected. Sexual harassment in any form is strictly prohibited and will not be tolerated. This Anti-Sexual Harassment Policy outlines our commitment to preventing sexual harassment, supporting victims, and addressing complaints with seriousness and confidentiality.

PURPOSE
The purpose of this policy is to define sexual harassment, establish guidelines for preventing and addressing it, and create an environment where everyone can work without fear of discrimination, harassment, or retaliation.

SCOPE

This policy applies to all employees, contractors, interns, and anyone representing the company, whether on company premises or off-site at business-related events, including virtual meetings. It governs interactions between employees, as well as those with clients, suppliers, and other business contacts.

WHAT CONSTITUTES SEXUAL HARASSMENT?

Sexual harassment includes unwelcome or inappropriate conduct of a sexual nature that may be verbal, non-verbal, visual, or physical. Examples of prohibited conduct include, but are not limited to:

Unwanted sexual advances or propositions
Inappropriate or suggestive comments, jokes, or gestures
Displaying offensive images or materials
Inappropriate physical contact, such as touching, hugging, or patting
Verbal abuse or insults of a sexual nature
Staring, leering, or making sexually suggestive expressions
Retaliation for rejecting advances or reporting harassment

REPORTING SEXUAL HARASSMENT

Employees and individuals affiliated with the company are encouraged to report any incidents of sexual harassment promptly. Reports may be made in person, by email, or through our confidential reporting channels. All reports will be treated with the highest level of confidentiality and handled in a sensitive and timely manner.

To report an incident, please contact:

Human Resources: hr@geohan.com

Confidential Reporting Channel: compliance@geohan.com

INVESTIGATION AND RESPONSE

Upon receiving a complaint, our company will:

1.Conduct a prompt, thorough, and impartial investigation. Take steps to protect the safety, confidentiality, and rights of both the reporting individual and the accused.

2. Provide support resources for the complainant, including counseling or leave, if needed.

3. Take appropriate disciplinary actions if the investigation finds misconduct, which may include warnings, suspension, termination, or legal action, depending on the severity of the harassment.

4. Take appropriate disciplinary actions if the investigation finds misconduct, which may include warnings, suspension, termination, or legal action, depending on the severity of the harassment.

NON-RETALIATION

Retaliation against anyone who reports sexual harassment or participates in an investigation is strictly prohibited. If you believe you have faced retaliation, report it immediately through the channels provided above. Our company will investigate and address any retaliation claims swiftly.

PREVENTION AND AWARENESS

Our company is committed to creating an environment where harassment is not tolerated. We take the following proactive measures: All employees will receive regular training on identifying, preventing, and reporting sexual harassment. The policy and reporting procedures will be communicated to all staff and available on our website and employee portals. We foster a culture where employees feel safe to speak up and report concerns without fear.

POLICY REVIEW AND UPDATES

We are committed to continuously improving this policy to adapt to changing laws and best practices. This policy will be reviewed and updated periodically to ensure its effectiveness and relevance.

CONTACT

For more information or questions about our Anti-Sexual Harassment Policy, please contact our HR team at hr@geohan.com.

Our company is committed to safeguarding the privacy and personal data of our employees, clients, and other stakeholders. This Personal Data Protection Policy outlines how we collect, use, store, and protect personal data in compliance with applicable data protection laws and regulations.

PURPOSE
The purpose of this policy is to ensure transparency in how we handle personal data and to assure our stakeholders that their personal information is treated with respect, confidentiality, and care. We are dedicated to protecting personal data from misuse and unauthorized access while upholding our legal obligations.

SCOPE
This policy applies to all personal data collected, processed, and stored by our company in relation to employees, clients, business partners, and other individuals. It governs all operations, services, and activities conducted by our company where personal data is handled.

COLLECTION OF PERSONAL DATA
We collect personal data only when necessary to fulfill legitimate business purposes or as required by law. Personal data we may collect includes, but is not limited to:

Contact details (e.g., name, address, phone number, email)
Identification details (e.g., ID numbers, passport numbers)
Employment information (e.g., position, salary, work history)
Financial information (e.g., bank details, transaction history)
Any other information that individuals voluntarily provide to us

USE OF PERSONAL DATA
We use personal data only for the purposes for which it was collected or for closely related business activities. Such purposes include:

Human resource management, including recruitment and payroll processing
Providing and improving services for our clients and partners
Compliance with legal and regulatory requirements
Responding to inquiries, feedback, or requests
Enhancing security and preventing frau

PROTECTION OF PERSONAL DATA
We implement stringent security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction. These measures include: Physical, technical, and administrative safeguards Access control and restricted data sharing Regular monitoring and testing of security protocols Employees handling personal data are trained in best practices for data protection and confidentiality.

DATA RETENTION
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Once personal data is no longer needed, we securely delete or anonymize it to prevent unauthorized access.

RIGHTS OF DATA SUBJECTS
We respect the rights of individuals regarding their personal data, which may include:

Right to Access: Individuals may request access to their personal data held by us.
Right to Correct: Individuals may request corrections to any inaccurate or outdated personal data.
Right to Withdraw Consent: Where applicable, individuals may withdraw consent to the processing of their personal data.
Right to Erasure: Individuals may request the deletion of personal data, subject to legal and contractual obligations.

Requests to exercise these rights can be submitted via confidential@geohan.com. We will respond promptly in accordance with legal requirements.

THIRD-PARTY DISCLOSURE
We do not share personal data with third parties except:

When required by law or government authorities
With trusted service providers who help us conduct our business, under strict confidentiality agreements
With the individual’s consent, where applicable

CHANGES TO THIS POLICY
We may update this Personal Data Protection Policy to reflect changes in our practices or relevant laws. Significant changes will be communicated through our website or other appropriate channels.

CONTACT
If you have questions or concerns regarding this policy or your personal data, please contact our Data Protection Officer at confidential@geohan.com.

Our company is dedicated to maintaining the highest standards of integrity, honesty, and transparency in all our business activities. This Code of Conduct and Ethics Policy provides a framework of principles and expectations to guide the behavior of all employees, contractors, partners, and other stakeholders in conducting business on behalf of our company.

PURPOSE

The purpose of this policy is to ensure that all members of our organization act in a manner that reflects our company values, complies with applicable laws, and upholds our commitment to ethical business practices. This policy is designed to foster a respectful, safe, and professional work environment for everyone.

SCOPE

This Code of Conduct and Ethics Policy applies to all employees, contractors, directors, and other representatives acting on behalf of the company. It governs all professional interactions, both within and outside of the organization, that may impact our company, clients, or stakeholders.

CORE PRINCIPLES

1.Integrity and Honesty

Act with integrity in all actions and uphold truthfulness and accountability.
Avoid dishonest, deceptive, or misleading conduct.
Represent our company accurately and avoid conflicts of interest.

2.Compliance with Laws and Regulations

Follow all applicable laws, regulations, and company policies in every business activity.
Seek guidance on any legal compliance matters when unsure.
Report any violations of law or unethical behavior immediately.

3.Respect in the Workplace

Treat colleagues, clients, and stakeholders with respect, dignity, and fairness.
Promote an inclusive, diverse workplace free from discrimination, harassment, or bullying.
Encourage open communication, teamwork, and cooperation.

4. Confidentiality and Data Protection

Safeguard all company, client, and personal data by maintaining strict confidentiality.
Do not disclose confidential information to unauthorized parties.
Use personal data responsibly, in compliance with our Data Protection Policy.

5. Avoiding Conflicts of Interest

Avoid situations where personal interests conflict with company interests.
Disclose any potential conflicts of interest to management.
Ensure that business decisions are made solely in the best interest of the company.

6. Professionalism and Accountability

Demonstrate professionalism, diligence, and accountability in all tasks and responsibilities.
Exercise sound judgment and report errors, mistakes, or concerns transparently.
Take responsibility for actions and contribute positively to the company's goals.

7. Fair Dealing

Conduct business fairly, with respect for competition and market practices.
Avoid practices that could unfairly disadvantage clients, competitors, or partners.
Honor all contractual commitments and strive to deliver quality in all services.

8. Health, Safety, and Environmental Responsibility

Follow all health and safety protocols to ensure a safe workplace.
Report hazardous conditions or unsafe practices immediately.
Minimize environmental impact and contribute to sustainable practices whenever possible.

9. Use of Company Assets

Use company resources responsibly and for business purposes only.
Safeguard company property, including physical assets, intellectual property, and proprietary information.
Avoid waste, misuse, or unauthorized use of company resources.

REPORTING AND COMPLIANCE

Employees or stakeholders who observe violations of this Code of Conduct are encouraged to report concerns through our confidential reporting channels. Retaliation against anyone who reports concerns in good faith is strictly prohibited.

DISCIPLINARY ACTIONS

Violations of this Code of Conduct and Ethics Policy may result in disciplinary action, including warnings, suspension, or termination, depending on the severity of the infraction. Severe violations may be reported to legal authorities as required by law.

POLICY UPDATES

Our company may update this Code of Conduct and Ethics Policy as necessary to reflect changing regulations or company practices. Changes will be communicated to all employees and will be posted on our website.

CONTACT

For questions or additional guidance regarding this policy, please contact our HR Team at hr@geohan.com.

Our company is committed to conducting business with integrity, transparency, and accountability. This Conflict of Interest Policy establishes guidelines to help employees, contractors, board members, and other representatives of our company avoid conflicts of interest that could compromise their responsibilities to the company or harm our reputation.

PURPOSE

The purpose of this policy is to identify, disclose, and manage actual or potential conflicts of interest to protect the company’s integrity and ensure that all business decisions are made in the best interest of our organization and stakeholders.

SCOPE

this policy applies to all employees, officers, board members, contractors, and anyone acting on behalf of the company. It covers all work-related interactions, transactions, and activities conducted for or on behalf of the company.

WHAT CONSTITUTES A CONFLICT OF INTEREST?

A conflict of interest occurs when personal, financial, or other interests interfere with or have the potential to interfere with an individual’s duties and loyalty to the company. Situations that may create conflicts of interest include, but are not limited to:

1. Personal Relationships: Hiring, supervising, or working closely with a family member or close personal friend.

2. Outside Employment or Business Interests: Holding a position, financial interest, or engaging in work for another company that competes with, provides services to, or could influence decision-making for our company.

3. Financial Interests: Owning or having a substantial financial interest in a company that does business with or competes with our company.

4. Gifts and Entertainment: Accepting gifts, favors, or entertainment from a client, supplier, or competitor, which could influence or appear to influence decisions.

5. Use of Company Assets: Using company property, resources, or confidential information for personal gain or for the benefit of another organization.

DISCLOSURE OF CONFLICTS OF INTEREST

Employees and other representatives are required to disclose any real or potential conflicts of interest as soon as they arise. Disclosures should be made in writing to a direct supervisor, manager, or the Human Resources Department. Our company will review disclosed conflicts and determine the appropriate course of action. Some conflicts may require individuals to recuse themselves from specific decisions, while others may require a more comprehensive solution.

MANAGING CONFLICTS OF INTEREST

Where a conflict of interest has been identified, the company may take the following steps to mitigate or eliminate the risk:

Recusal from Decision-Making: Individuals may be asked to abstain from participating in decisions related to the conflict.
Divestment: In cases of significant financial conflicts, employees may be asked to divest from the conflicting interest.
Reassignment of Duties: Duties may be reassigned to remove any influence the individual may have on related decisions.
Other Measures: Depending on the situation, the company may take additional measures to address the conflict as deemed appropriate

PROHIBITED ACTIVITIES

To maintain the integrity of our organization, the following activities are strictly prohibited:

Engaging in outside employment or business that directly competes with the company.

Using company assets, resources, or confidential information for personal gain or the benefit of another company.

Engaging in any conduct or decision-making that benefits a personal relationship or financial interest over the company’s interests.

COMPLIANCE AND ACCOUNTABILITY

All employees and representatives are responsible for understanding and complying with this policy. Failure to disclose conflicts of interest or engaging in prohibited activities may result in disciplinary action, up to and including termination.

NON-RETALIATION

The company prohibits retaliation against any individual who discloses a conflict of interest or participates in an investigation related to this policy. Retaliation claims will be investigated and addressed promptly.

POLICY REVIEW AND UPDATES

We are committed to keeping this policy up-to-date and will periodically review and revise it to reflect best practices and changes in applicable laws and regulations.

CONTACT

For questions or to disclose a conflict of interest, please contact our Human Resources Department at hr@geohan.com.

Our company is committed to fostering a diverse, equitable, and inclusive workplace where everyone feels respected, valued, and empowered. We believe that diversity in backgrounds, perspectives, and experiences strengthens our organization, drives innovation, and enhances our ability to serve our clients and communities.

PURPOSE

This policy aims to outline our commitment to diversity and inclusion (D&I) and the principles that guide our actions to create a welcoming environment for all employees, partners, clients, and stakeholders. We strive to build a culture where everyone can thrive, irrespective of race, ethnicity, gender, sexual orientation, disability, age, religion, or any other identity.

SCOPE

This policy applies to all employees, contractors, clients, and partners. It governs all aspects of our operations, including recruitment, hiring, professional development, promotions, interactions, and work practices.

POLICY STATEMENTS

1. Inclusive Hiring and Recruitment : We are committed to attracting, hiring, and promoting individuals from a broad range of backgrounds. Our recruitment practices focus on reducing unconscious bias, and we seek to reach a diverse pool of qualified candidates through inclusive job postings, partnerships with diverse organizations, and fair interview processes.

2.Equal Opportunity for Growth and Development : Our company offers equal access to training, mentorship, and professional growth opportunities. We actively support the advancement of underrepresented groups and are committed to ensuring all employees have the resources and encouragement to excel in their careers.

3. Respectful Workplace Culture : We promote a respectful workplace where all individuals are treated with dignity. Our policies strictly prohibit discrimination, harassment, or any conduct that undermines inclusivity. We expect all employees to uphold these values in their interactions with colleagues, clients, and stakeholders.

4. Diverse Perspectives in Decision-Making : We encourage diversity of thought and value the unique contributions of all employees. Our leadership and teams work to include diverse voices in decision-making processes to ensure well-rounded, inclusive perspectives shape our strategies, products, and services.

5. Accommodation and Accessibility : We are committed to providing reasonable accommodations to ensure accessibility for all employees and applicants. Our facilities, resources, and tools are designed to support the diverse needs of our workforce and enhance the inclusion of people with disabilities.

REPORTING AND ACCOUNTABILITY

We take concerns regarding discrimination, harassment, or inequality seriously. Employees or partners who observe or experience behavior that conflicts with our D&I principles are encouraged to report it through our confidential reporting channels. Our commitment to non-retaliation protects those who raise concerns in good faith.

CONTINUOUS IMPROVEMENT

Diversity and inclusion are ongoing priorities for our company. We regularly assess our policies, practices, and workplace culture to ensure we are making meaningful progress. Our leadership team is dedicated to continuous learning and promoting diversity and inclusion at all levels of our organization.

CONTACT

For questions or further information about our Diversity & Inclusion Policy, please contact hr@geohan.com.

1. INTRODUCTION

1.1. Geohan Holding and its subsidiary, Geohan Sdn. Bhd., Geohan Equipment Sdn. Bhd., Geohan Mix Sdn. Bhd. (collectively known as Geohan) adopts this Anti-Bribery Policy, setting out the responsibilities to its subsidiary/ies, directors, employees and business associates of Geohan to committing and upholding zero-tolerance position on bribery and corruption by complying to the Malaysian Anti-Corruption Commission Act 2009 (MACC Act. 2009) and any of its amendments or re-enactments by the relevant authority from time to time.

1.2. This anti-bribery Policy sets out parameters to prevent the occurrence of bribery and corrupt practices for the Directors, Top Managements, and Employees as well as all business associates of Geohan.

2. POLICY STATEMENT

2.1. Geohan is committed to conducting business ethically and honestly and is committed to implementing and enforcing systems to prevent bribery. Geohan has zero tolerance for bribery and corrupt activities. We are committed to ethical transparency, fairness and integrity in all business practices and relationships, wherever we operate.

2.2. Geohan will continuously uphold all laws relating to anti-bribery and corruption within Malaysia. We are bound by the laws and regulations in Malaysia, including but not limited to the Malaysian Penal Code (revised 1977), the Malaysian Anti-Corruption Act 2009 (revised 2018), and the Malaysian Companies Act 2016.

2.3. Geohan recognizes that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If Geohan is found to have taken part in any corrupt activities, we may be subjected to heavy punishment, be excluded from tendering for public contracts, and face severe damage to our reputation. It is with this in mind that we commit to prevent bribery and corruption in our business and take our legal responsibilities seriously.

3. SCOPE OF POLICY

3.1. This anti-bribery Policy applies to Directors, Top Managements, Managers, Employees, people connected to and Business Associates of Geohan as well as Public officials, Trustees, Board of any regulated body.

3.2. “Directors” include all independent and non-independent Directors, executives and non- executive Directors of Geohan and shall also include alternate or substitute Directors.

3.3. “Employees” mean all employees whether temporary, fixed-term, permanent or trainees.

3.4. “Business Associates” include clients, consultant, contractors, sub-contractors, suppliers, casual workers, agency staff, agents, sponsors, joint-venture partners, investors, business partners and any other person or persons who associate with Geohan.

3.5. “Office officials, Trustee, Board” include officials of any governments, government’s agencies or any regulatory, statutory or administrative bodies, whether local or foreign”

3.6. Any business dealings Geohan makes with business associates are subject to clear contractual terms, including specific provisions that require the business associates to comply with bribery and corruption practices relating to the Anti-Bribery and Corruption Act (MACC Act 2009).

3.7. This Policy is supplemental to and shall be read in conjunction with Geohan’s code of ethics and conduct, whistle blowing Policy and the MACC Act 2009.

4. DEFINITION OF BRIBERY

4.1. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or an advantage so to induce or influence an action or decision.

4.2. Bribery is not limited to the act of offering a bribe. If an individual is on receiving the end of a bribe and they accept it, they are also breaking the law.

4.3. Bribery is illegal. Directors, Employees and Business Associates must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as agent or distributor). They must not accept bribes to any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance appointed person or Human Resources Department.

5. GIFT, ENTERTAINMENT, TRAVEL, HOSPITALITY DONATION AND SPONSORSHIP

5.1. Geohan has adopted a “No Gift” Policy whereby, subject only to specified exceptions, all directors, employees and associates acting for or on behalf of Geohan Group are prohibited from, directly or indirectly receiving and/or providing gifts.

5.2. Definition of Gifts are as below: -

Any gift of cash or cash equivalent. Cash equivalent could be in the form of vouchers, discounts, coupons, shares and commission etc.
Any gift involving parties engaged in a tender or competitive bidding exercise, purchasing contracts and biddings.
Any gift that comes with a direct/indirect suggestion, hint, understanding or implication that in return for the donation some expected or desirable outcome as required.
Any gift that would be illegal or in breach of local corruption laws. The term gift also refers to favours, advantages and preferential treatments as well as any form of entertainment provided to the recipient even if the giver is not physically present.

5.3. The only allowed type of gift-giving to external parties and receiving from external parties is corporate gifts. Any gift-giving and receiving shall not be used to influence business decisions. “Corporate Gift” means something given from one organisation to another organization or individual. Corporate gifts may also be promotional items given out equally to the general public at events, trade shows and exhibitions as a part of building the Company’s brand. The gifts are given transparently and openly, with the implicit or explicit approval of all parties involved. Corporate gifts normally bear the Company name and logo. Examples of corporate gifts include items such as table calendars, pens, notepads and plagues. Any receiving and giving of corporate gifts must fulfil the following conditions:

i) The giving and receiving of the gift must be done in an open and transparent manner.

ii) There must be no expectation of any specific favour or improper advantages from the intended recipients.

iii) The gifts are limited customary and lawful under the circumstances.

iv) Such gifts do not have or are perceived to have (by either the giver or the receiver), any effect on actions or decisions.

v) The independent business judgement of the intended recipients must not be affected.

vi) There must not be any corrupt/criminal intent involved

vii) The giving and receiving of the gift and hospitality must be done in an open and transparent manner

6. CHARITABLE DONATION AND SPONSORSHIP

6.1. Geohan allows charitable donations and sponsorships for a legitimate reason. General guideline for donations & sponsorship: All donations and sponsorships requests must comply with the following criteria:

Contributions are allowed by applicable laws.
Obtain all necessary internal and external authorisations.
Be made to establish entities having adequate organisational structures to guarantee the proper administration of the funds.
Accurately stated in the Company’s accounting books and records.
Not to be used as a means to cover up an undue payment or bribery.

6.2. Specific guidelines for donation and sponsorship

6.2.1. Donations

All donations of any kind must be transparent
•n any instance of charitable giving there must be an accurate receipt or letter of acknowledgement for any donation

6.2.2. Sponsorships - check and ensure that sponsorship should:

Be objective and should not be based solely on personal preference of the Company’s directors, officers and employees.
Conduct due diligence, especially pertaining to the public activity and background of potential beneficiaries.

7. ENTERTAINMENT

7.1. Providing Entertainment

It is a common practice within the business environment to provide entertainment for starting business relationship. Geohan recognises the need to provide reasonable and proportionate entertainment under appropriate circumstances. Our eligible employees are allowed to offer appropriate and proportional entertainment that is legal and reasonable within the scope of their work as part of business networking as well as a measure of goodwill towards the recipients with good judgement.

While the act of hospitality through entertainment is a central part of business etiquette, directors and employees are strictly prohibited from providing or offering entertainment with a view to improperly causing undue influence on any party in exchange for some future benefit or result. Any acts of this nature, whether provided directly or indirectly through an intermediary, may be construed as an act of bribery and contrary to the general values and principles of Geohan.

7.2. Accepting Entertainment

Geohan recognizes that the occasional acceptance of reasonable entertainment provided by the external parties in the normal course of business is important to foster good business relationships.

It is important for employees and directors to exercise proper care and judgement before accepting entertainment offered or provided by a third party. This is not only to safeguard the Company’s reputation, but also to protect employees and directors from allegations of impropriety or undue influence or worse, corruption.

Accepting entertainment such as occasional business meals and attending events as part of usual business networking where the giver is present is acceptable and does not need to be reported. However, if the giver is absent, it is treated as a “Gift” and it must be declared to the Human Resource Department.

All employees and directors are required to comply with the policies and procedures of your Human Resource Department concerning receiving entertainment from third parties.

8. POLITICAL CONTRIBUTION

Geohan does not allow to make donations, whether in cash, kind, or by any others, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

9. FACILITATION PAYMENTS AND KICKBACKS

Geohan does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for routine governmental action. We recognise that they tend to be made by low-level officials to secure or speed up the performance of a certain duty or action.

10. BUSINESS ASSOCIATES

All business associates (including external providers such as consultants, advisors, and agents) acting on behalf of Geohan are required to comply with this Policy, the Geohan Code of Business Ethics, and all other policies as it relates to them.

In circumstances where Geohan retains controlling interest, such as in certain joint venture agreements, business associates are required to adhere to the Anti-Bribery Corruption Policy and Geohan’s Code of Business Ethics. Where Geohan does not have a controlling interest, associates are encouraged to comply with the same.

Due diligence should also be carried out with regards to any business associates intending to act on Geohan’s behalf as an agent or in other respective roles, to ensure that the entity is not likely to commit an act of bribery or corruption in the course of its work with Geohan.

The extent of the due diligence should be based on bribery and corruption risk assessment. Due diligence may include research through relevant databases, checking for relationships with public officials, self-declaration, and documenting the reasons for choosing one particular Business Associate over another. The results of the due diligence process must be documented, retained for at least seven years and produced on request by the custodian of the process.

Geohan shall include standard clauses in all contracts with business associates enabling the Company to terminate the contract in the event that bribery or an act or corruption has proven to have occurred. Additional clauses may also be included for business associates acting on Geohan’s behalf, where a more than minor risk has been identified

11. RESPONSIBILITIES OF TOP MANAGEMENT, DIRECTORS AND EMPLOYEES

Top management, directors and employees of Geohan are required to carry out those responsibilities and comply with the Company’s anti-bribery and corruption Policy. In particular the roles of all directors and employees include the followings:

Familiar with applicable requirements of directions of the Policy and communicate them to subordinates.
Promptly record all transactions and payments in Geohan’s books and record accurately and with reasonable details.
Ask the Human Resource department if any questions about this Policy arise or if there is a lack of clarity about the required action in a particular situation.
Always raise suspicious transactions and other “red flags” (indicators of bribery or corruption) to immediate superiors for guidance in the next course of action.
Be alert to indications or evidence of possible violations of this Policy.
Promptly report violations or suspected violations through appropriate channels.
Attend required anti-bribery and corruption training as required according to position
Not to misuse their position or Geohan’s name for personal advantage.

12. CONFLICTS OF INTEREST

Conflicts of interest arise in situations where there is personal interest that could be considered to have potential interference with objectivity in performing duties or exercising judgement on behalf of the Company. All personnel should avoid situations in which personal interest could conflict with their professional obligations or duties. Personnel must not use their position, official working hours, Company’s resources and assets, or information available to them for personal gain or to the Company’s disadvantage.In situations where a conflict does occur personnel is required to declare the matter as per the Employees Handbook.

13. STAFF DECLARATION

i) All staff of Geohan must read, understand and comply with the information contained within this Policy. A copy of their declaration by the employee shall be documented and retained by the Human Resource Department for the duration of the employees’ employment.

ii) If any employee breaches this Policy or implicated in any bribery and corruption-related incident, Geohan Group reserves the right to impose disciplinary action including termination of employment contract and dismissal.

14. ANTI-BRIBERY AND ANTI CORRUPTION COMPLIANCE

The group’s appointed risk management committee and its members will monitor and maintain an anti-bribery and corruption compliance and review the implementation of this Policy, regularly considering its sustainability, adequacy and effectiveness.

The group’s appointed risk management committee and its members shall conduct regular internal control and procedure to identify the bribery and corruption risk that will potentially affect the group.

15. TRAINING AND AWARENESS

Geohan conducts an awareness program for all its personnel on the Company’s position regarding anti- bribery and corruption, integrity and ethics.

Training shall be provided on a regular basis, in accordance with the level of bribery and corruption risk related to the position. Training should be provided to personnel who are:

A. New to the Company

Human Resource Department shall maintain records to identify which Geohan personnel have received training and update the training schedule in conjunction with Anti-Bribery and Corruption Committee.

16. POLICY VIOLATIONS

Adherence to this Policy and Guidelines is critical to the smooth running of the business and is for the common good of Geohan.

Geohan prohibits and has zero-tolerance for bribery and corruption in any form. Any employee or associate found guilty of bribery and corruption shall be subject to severe disciplinary action, including dismissal of employment or termination of the contract as the case may be and may also be subject to prosecution under the law of Malaysian Anti-Corruption Commission Act 2009.

Official dealings between Geohan and the parties shall be terminated or discontinued if they are found offering, promising, giving or soliciting any bribe or gratification to Geohan Group employees and reports shall be made to Malaysian Anti-Corruption Commission (MACC) for investigation upon approval by Geohan.

17. PERIODIC REVIEW

This Policy will be reviewed as and when required to ensure effectiveness and compliance with the governing legislation and regulatory requirement.

18. BOARD APPROVAL

This Policy was reviewed and approved by the Board of Directors of the Company on 12/12/2024.