Whistleblowing Policy

Commitment

Qube Integrated Malaysia Sdn. Bhd. ("Qube" or "the Company") is committed to conducting its business with the highest standards of integrity, transparency, accountability, and ethical conduct.

The Company encourages employees, directors, contractors, consultants, suppliers, business partners, and members of the public to report any actual or suspected misconduct, unethical behaviour, or violation of applicable laws, regulations, or Company policies.

Qube is committed to ensuring that all genuine concerns are taken seriously, investigated fairly, and handled in a confidential and impartial manner.

What Should Be Reported?

A report may be made if you have reasonable grounds to believe that improper conduct has occurred or is likely to occur. This includes, but is not limited to:

• Bribery and corruption
• Fraud or financial irregularities
• Forgery, embezzlement, or criminal breach of trust
• Money laundering
• Theft, misappropriation, or misuse of Company assets
• Abuse of authority or power
• Conflict of interest
• Unauthorised disclosure of confidential information
• Breach of Company policies or procedures
• Harassment (including sexual harassment), bullying, or discrimination
• Unethical or dishonest business practices
• Violations of applicable laws or regulations
• Any other conduct that may adversely affect the Company, its employees, stakeholders, or the public interest

Making a Report

Reports should be made in good faith and based on a reasonable belief that the information provided is true and accurate to the best of the whistleblower's knowledge.

Whistleblowers are encouraged to submit their reports using the Company’s Whistleblowing Form, which may be obtained from the Whistleblowing Unit.

Where possible, reports should include:

• A description of the alleged misconduct;
• The names of individuals involved (if known);
• The date, time, and location of the incident;
• Any supporting documents or evidence available; and
• Contact details of the whistleblower (optional as reports may be made anonymously), to facilitate further communication if necessary.

Knowingly making false, malicious, or misleading allegations may result in appropriate disciplinary and/or legal action and the loss of protection under this Policy.

Confidentiality

All whistleblowing reports will be treated with the highest level of confidentiality.

Reports will be received and reviewed by the Company's Whistleblowing Unit, which comprises representatives of the Board Chairman and the Finance, Compliance and Legal Departments. The identity of the whistleblower and any information that may identify the whistleblower will be protected to the fullest extent permitted by law.

Disclosure of the whistleblower's identity will only be made where:

• it is required by law;
• it is necessary for the purposes of a fair investigation or legal proceedings; or
• the whistleblower has provided consent.

The Company’s assurance of confidentiality can be fully effective only if the whistleblower likewise maintains the confidentiality of the report and of the investigation.

How to Report

Concerns may be reported through any of the following channels:

What Happens After a Report is Made

The Whistleblowing Unit will conduct an initial assessment of every report received to determine whether the concern raised falls within the scope of this Policy. The initial assessment will be completed within seven (7) working days from the date the report is received, and additional information may be requested from the whistleblower. If the case is closed at this stage, the Whistleblowing Unit will inform the whistleblower of the decision.

Where an investigation is warranted, it will be carried out by an independent investigation team or an external independent party. Investigations are generally expected to be concluded within thirty (30) to sixty (60) days, depending on the nature and complexity of the matter, and the whistleblower will be informed where additional time is required. All timeframes stated in this Policy are indicative only and may vary according to the circumstances of each case.

The whistleblower will be informed of the outcome of the investigation; however, the details of the findings will not be disclosed for reasons of confidentiality.

If the allegations are substantiated, appropriate disciplinary or legal action will be taken, which may include dismissal or termination of employment, reporting the matter to law enforcement authorities, or other measures deemed appropriate by Management or the Board.

External Reporting

Where appropriate, individuals may also report suspected improper conduct directly to the relevant enforcement authorities in accordance with the provisions of the Whistleblower Protection Act 2010 (Malaysia) and any other applicable laws. Disclosures made under the Act must be made directly to the relevant enforcement agency, and any investigation or action taken thereafter will be in accordance with the Act and independent of the procedures described in this Policy. Individuals are nonetheless encouraged to raise concerns through the Company’s internal reporting channels where appropriate, so that the Company may investigate, remedy the matter, and implement suitable corrective or preventive controls.

Good Faith Reporting

The Company encourages responsible reporting. A whistleblower is not required to prove the allegation but must have a genuine and reasonable belief that the information disclosed indicates improper conduct.

Reports made honestly and in good faith will not result in any adverse consequences, even if the allegation is ultimately unsubstantiated after investigation.

Protection Against Retaliation

No unfair treatment, reprisal, retaliation, or adverse action shall be taken against a whistleblower who makes a disclosure in good faith under this Policy. This includes dismissal, demotion, harassment, discrimination, disciplinary action, or any other form of retaliation by any person exercising authority over the whistleblower.

Any retaliation against a whistleblower who has made a disclosure in good faith will result in disciplinary action against the responsible party.

Review of this Policy

This Policy will be reviewed at least once every three (3) years, or as necessary, to ensure its continued relevance, compliance with applicable laws, and alignment with the Group’s governance standards. This Policy should be read in conjunction with the Company’s Anti-Bribery and Anti-Corruption Policy and Guidelines and other relevant internal policies.

Qube Integrated Malaysia Sdn. Bhd. remains committed to maintaining a culture of integrity, ethical business practices, and zero tolerance for bribery, corruption, fraud, and misconduct. The Company encourages everyone associated with Qube to speak up whenever they become aware of conduct that may compromise these principles.