Whistleblowing Policy

SK Luxury Construction Sdn. Bhd. (“the Company”) is committed to the highest standards of integrity and accountability. This Policy provides a safe and confidential channel for raising genuine concerns about improper conduct, and sets out the protection available to those who speak up in good faith.

1. Purpose

The purpose of this Policy is to encourage the early reporting of improper conduct connected with the Company, and to reassure those who report that they may do so without fear of reprisal. It is aligned with the principles of the Whistleblower Protection Act 2010.

2. Who Can Raise a Concern

This Policy is available to all directors, employees, subcontractors, suppliers, clients and other stakeholders who have a genuine concern relating to the Company’s business or personnel.

3. What Should Be Reported

Concerns about improper conduct include, but are not limited to:

• bribery, corruption, kickbacks or other breaches of the Anti-Bribery & Anti-Corruption Policy;
• fraud, theft, or misuse of Company or client funds or assets;
• breach of law, regulation or contractual obligation;
• serious safety, health or environmental risks at project sites or the workplace;
• falsification of records, reports or claims;
• abuse of authority, or conduct that endangers others; and
• the deliberate concealment of any of the above.

4. What Is Not Covered

This Policy is not intended for personal grievances relating to an individual’s own employment (such as pay or day-to-day management matters), which should be raised through the usual channels with Management.

5. How to Raise a Concern

Concerns may be raised in confidence through any of the following channels:

• Email: admin@skluxury.com.my (marked for the attention of the designated Integrity Officer);
• Whistleblowing / Incident Report Form: available on the Company’s website; and
• In person or in writing to a Director of the Company.

A concern should include as much relevant detail as possible — what happened, who was involved, and when — to allow it to be properly assessed. Concerns may be raised anonymously; however, providing contact details assists any follow-up.

6. Confidentiality

The identity of a person raising a concern in good faith will be kept confidential so far as is reasonably practicable, and disclosed only where necessary to investigate the matter or as required by law.

7. Protection from Retaliation

The Company will not tolerate any form of retaliation, detriment or victimisation against a person who raises a genuine concern in good faith. Any act of retaliation is itself a breach of this Policy and may result in disciplinary action.

8. How Reports Are Handled

Reports are assessed promptly and, where appropriate, investigated fairly and objectively. The Company treats reports seriously and will take suitable corrective action where wrongdoing is found. Feedback on the outcome will be provided to the person who raised the concern where it is appropriate and lawful to do so.

9. Good Faith

This Policy protects those who report genuine concerns honestly, even if they later prove to be mistaken. Knowingly making a false or malicious allegation is a misuse of this Policy and may result in disciplinary action.

10. Review

This Policy is reviewed periodically and updated as necessary.