Whistle Blowing Policy

---

Golden
Cougar is committed to conduct with the good standard of quality, honesty, transparency and accountability. To uphold our commitment and our integrity, we comply with policies and code of conduct. All employees and members are needed to have share responsibility to maintain the integrity by engaging with policies and code.

The Whistle Blowing policy is provided as an alternative route to raise concerns and to suggest anonymously by every employee.

Policy

The Whistle Blowing policy is provided with these statements.

• All employees can raise concern about wrong doing or suspicion of malpractices or activities that may be deemed illegal, without fear of retribution or losing jobs.
• Golden Cougar is provided reassurance that the employee will be protected from demotion, penalty and other reprisals.
• All Whistle Blower who make in good faith and without malice will be protected by the policy without any risk or jeopardy even if the concern turned out to be mistaken.

Issue to be /not to be concerned under the policy

The policy is intended to be concerned the following issues.

• Financial Frauds, Improper Accounting
• Corruption and Bribery
• Acts or omissions which are deemed to be against the Government and Company Laws, regulations or policies.
• Non adherence and breaches of company’s policies and code of conduct.
• Misuse of confidential information.
• Giving false or misleading information.
• Deliberate concealment of any of above matter or other acts of wrong doing.

Issue not to be concerned under this policy

• Acts or doing of employee’s personal behaviors not related to employment and company.
• Staff’s complaints about their employment
• Customer’s complaint about our services.

Responsibility and Procedures

• Responsibility for complying Whistle Blowing policy is appointed with site engineers and team leaders in seniority depend on their level of authority.
• Managing Director has a responsibility to take care seriously and consider with full sympathetic to all concerns.

Procedures

• Procedures for reporting concerns with the channels assuming full confidentiality and /or anonymity and two-way communication with the whistle – blower for any needed follow-up.
• First reporting contact should be your immediate supervisor or manager or Whistle blowing officer if appropriate or suitable.
• Alternatively, contact to the Head of Human Resource Department, if you unable to raise as in first channel or are not satisfied the outcome. Head of Legal and Compliance Department must also support offers.
• If the above channels have been followed and your concern still have (or) serious, you can contact to Managing Director either personally or via mail.([email protected])

Response

• The Whistle Blowing offer must investigate and resolve the matter of concern immediately. If the matter is difficult or complex or serious, the Whistle Blowing officer can offer support from other.
• The Whistle Blowing officer must ensure no victimization on the concern and need to response satisfactorily in accordance with laws and policies and feedback to the reporter.
• The Whistle Blowing officer must keep the information and identity of concerns unless they have to do so by law.
• If anyone who raise a concern that turn out to be malicious or in bad faith, disciplinary action will be dealt with.

Reporting and Reviewing

• The Whistle Blowing officer must report all received concerns, conducted outcome after investigation, action plans and area of improvement to the Executive Committee and to Managing Director as quarterly basis.
• Maintaining the records and documents of all concerns are mandatory for protection and reviewing of the issue and up to a proven duration by the Executive Committee.
• Contact Mail/ Phone No