internal control framework

PR1MA Group conducts all business in accordance with all applicable laws and regulations. Compliance with the law does not comprise the employees' entire ethical responsibility. Rather, it is a minimum, essential condition for the performance of the employees' duties.

There are complex, rapidly changing laws and issues which may affect an employee's personal conduct outside of the business environment. The employees are responsible for knowing and complying with all applicable laws and regulations and are urged to consult with PR1MA Group's respective Heads of Department as to questions concerning these laws and regulations.'

The employees shall not take any action on behalf of PR1MA Group which he or she knows or should reasonably know would violate any law or regulation. The employees shall not use any personnel or assets for any unlawful purpose. If an employee has any compliance questions relating to us or our business, he or she should consult Heads of Department within PR1MA Group.

PR1MA Group also conducts all business dealings with strict adherence to the Guidelines for Integrity Pact Implementation inProcurement ("Integrity Pact"). PR1MA Group are committed to ensuring that practices of corruption are not tolerated or encouraged in any sense within this Corporation and/ or its subsidiaries. The Integrity Pact underlines measures that should be taken when in the event that the Integrity Pact is breached.

While the following list is not exhaustive, some areas of improper activity that the employees should avoid include the following:

• making false, misleading, artificial, or fictitious entries in PR1MA Group's books and records;

• establishing or maintaining any secret or unrecorded funds of PR1MA Group's cash or other assets for any purpose;

• using PR1MA Group's funds or resources to support any Malaysian political party, candidate, or political campaign, without the prior review and approval from the MoC of PR1MA;

• paying or offering to pay bribes or kickbacks to government officials, those with whomPR1MA Group does business, or others, including substantial gifts or lavish entertainment;

• issuing or authorising the issuance of any false or misleading document;

• making any payment on behalf of PR1MA Group with the knowledge or intent that all or any part of the payment is or will be used for any purpose other than that described in the supporting documentation;

• preparing, filing, or authorising any false or materially incorrect document, including permit applications or reports, with any government agency or official properly requesting and entitled to such information; and

• directly discussing with or entering into agreements or understandings, including gentlemen's agreements or silent agreements with competitors on prices or bids, terms of sale, distributors or territories, customers, production levels, profit levels or other competitive information. It is not enough to remain silent during such a discussion; an employee must leave the discussion and leave the meeting if necessary.

The employees and the interested parties must be aware of the IntegrityPact and must sign and acknowledge the pact to refrain from participating incorrupt practices during the course of the procurement process until the completion of the project.

As a responsible organization, PR1MA is committed to contributing to the wellbeing of the people and nation in which it operates. In June 2017, PR1MA Management approved the PR1MA Corporate Social Responsibility (CSR), Donation, Gift & Sponsorship Policy for the following purposes:

• To formalise principles for PR1MA to engage in CSR, donation, and sponsorship activities;

• To ensure that all CSR, donation, and sponsorship rendered by PR1MA Group are aligned with PR1MA CSR strategy and business goals, maximise opportunity for corporate visibility, foster long-term business relationships and are within budget and resource limitations.

Active participation encompasses the following activities:

• making public statements, oral or written;

• publishing or distributing material that provides an impression of a partisan view to any issue between political parties;

• engage in canvassing in support of any candidate at an election to the "Dewan Rakyat" or to any State Legislative Assembly or any election to any office in any political party;

• act as an election agent or a polling agent or in any capacity for or on behalf of a candidate at an election to the Dewan Rakyat or to any State Legislative Assembly,

• stand for election for any post in a political party; and

• hold any post in any political party.

No Senior Management personnel representing PR1MA shall participate actively in political activities or wear any emblem of a political party without prior written approval from the MoC.

PR1MA Group recognises that conflict of interest can have significant impact to PR1MAGroup when it occurs. Conflicts of interest arise from financial or other business relationships with PR1MA Group, suppliers/ contractors or competitors that might impair, or appear to impair, the independence of any judgment on behalf of PR1MA Group. They may arise from their personal investing, their outside business activities, their consideration of our business opportunities and dealings with related parties.

As such, employees are under a continuing obligation to disclose any situation that presents a conflict of interest and must report the conflict as soon as the matter comes to their knowledge. Unless they obtain appropriate approval, they must promptly eliminate that conflict or competitive situation.

As it is impossible to describe every potential conflict of interest, we necessarily rely on our employees to exercise good judgment, to seek advice when appropriate and to adhere to ethical standards in the conduct of an employee's professional and personal affairs.

policy Statement

PR1MA Corporation Malaysia ("PR1MA or the "Corporation") and its subsidiaries (the "Group") are committed to values of transparency, integrity, impartiality and accountability in the conduct of its business and affairs. PR1MA expects wrongdoings such as fraud, corruption, serious financial impropriety and gross mismanagement to be reported and it facilitates this through internal mechanisms.

objective

This policy is designed to facilitate the making of a disclosure as early as possible in any wrongdoings, to protect a whistleblower from reprisal as a direct consequence of making a disclosure and to treat both the whistleblower and alleged wrongdoer fairly.

scope

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reporting channels

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disclosure of identity

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poison pen letter (surat layang)

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type of wrongdoings

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whistleblower protection

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consequences of wrongful disclosure

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notification of outcome of disclosure

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whistleblowing procedure chart

The Corruption-Free Pledge (better known as IBR) is an initiative introduced by the Malaysian Anti-Corruption Commission (MACC). The IBR places emphasis on the pledge and oath voluntarily taken by an organisation's leadership and members in an individual capacity to hold each of them accountable and responsible for carrying out their duties and to hinder them from engaging in any corruption misconduct throughout their tenure.

Through the initiative, PR1MA shows leadership by example apart from supporting the initiatives undertaken by the MACC to be in line with the government's commitment to achieve an aspiration for our beloved country heading towards being a country of integrity and anti-corruption.

Implementation the IBR will reflect the face of the organisation that is clean and free from corruption, and at the same time create a network of cooperation between PR1MA and MACC in the joint effort to combat corruption and abuse of power.