Navia is committed to the highest possible standards of ethical, moral, and legal conduct. Consistent with this commitment, the policy aims to support good management practices and sound corporate governance practices.
This policy aims to provide a structured mechanism for employees and others to rise or report concerns about ongoing or suspected wrongful activities or wrongdoings to provide reassurance that they will be protected from reprisals or victimization for whistle-blowing in good faith.
For the purpose of this policy, the wrongful activities or wrongdoings refers to any potential violations or concerns relating to any laws, rules, regulations, acts, ethics, integrity and business conduct, including any violations or concerns relating to malpractice, illegal, immoral, embezzlement and fraudulent activities which will affect the business and image of Navia.
The Board of Directors (“BOD”) of Navia has a stewardship responsibility to communicate the requirements of this policy and to guide the organisation in dealing with concerns arising from wrongful activities or wrongdoings.
The Policy of the BOD is:
To encourage active and moral obligation to report wrongdoings All employees and others are required to report any ongoing or suspected wrongful activities or wrongdoings at the earliest possible stage through the proper channel of reporting so that immediate action can be taken.
To useinternaldisclosure to report wrongdoings As far as reasonable, internal disclosure is encourage and used to avoid public crisis.
To protect the whistle-blower Where the disclosure is made in good faith, the whistle-blower will be protected against victimization or other adverse treatment.
To ensure appropriate and fair disciplinary actions All actions taken against the alleged wrongdoers would be fair and without prejudice.
To require that an effective whistle-blowing guideline is established and maintained by Navia
Whistle-blowing guideline must be sufficient to:
Establish a formal and robust whistle-blowing guideline, including hotline accessibility;
Prohibit legal sanctions for retaliatory action taken against the whistle-blower;
Establish timely, feedback, respond and remedial and/or corrective action;
Ensure that this policy is properly communicated to all employees;
Establish procedures to maintain records confidentiality and retention; and
Embed integrity, transparency and accountability within the business
Reporting Mechanisms Employees are encouraged to advise the Board if they become aware of or believe that any of the following activity is taking place in Navia.
Failure to comply with legal obligations;
Criminal offence;
Corruption or fraud;
Misuse or abuse of Navia's funds or assets;
Gross mismanagement within Navia;
Serious financial irregularity or impropriety within Navia;
Serious breach of Navia’s Code of Business Conduct And Ethics or Conflict Of Interest Code for its employees and directors;
Actions which endanger the health or safety of employees or the public;
Failure to comply with the provisions of the Government Laws and Regulations where the wrongdoer, knowingly, disregards or does not comply with such provisions;
Knowingly directing or advising a person to commit any of the above wrongdoings; and
Any action which is intended to conceal any of the above.
For the benefit of the employees and to maintain each complaint in strict confidence, Navia has established email address and mailing address to be managed by Whistle-blowing Unit of Navia, and employees may report the suspected or actual illegal acts via these methods. The details are as follows:
Operating hours Sunday to Thursday ( 8.30 am to 5.30 pm)
Address Navia Whistle-blowing Unit Navia Network Sdn Bhd No. 28-01-02, Jalan Setia Tropika 1/18 Taman Setia Tropika, 81200w Johor Bahru, Johor, MALAYSIA
Email address wbu@navia.com.my Navia shall not permit any form of intimidation or retaliation against an employee by way of, but not limited to, discharge, demotion, suspension, threats, harassment or any other manner of discrimination with respect to an employee’s terms or conditions of employment. In respect of an employee who reports a suspected violation in good faith and is not engaged in questionable conduct, the company will attempt to keep its discussions and actions confidential to the greatest extent possible. In the course of investigation, the company may need to share information with others on a “need to know” basis.
The action taken will depend on the nature of the items inquiry. Initial inquiries will be made in respect of all reports received, to determine the nature and extent of further investigation.
A follow up report will be provided to a complainant after the initial enquiry. If an investigation is done, a summary of the findings of the investigation will be given to the complainant.
The Board of the Navia will exercise the oversight function over the administration of the policy.
Modification Navia may modify this Policy to maintain compliance with applicable laws and regulations or accommodate organisational changes within the Company.
