1. Purpose

Corporate FinEdge Management Services and, where relevant, its related corporations, affiliated businesses, associated firms, representatives and service providers involved in carrying on business with or for Corporate FinEdge Malaysia (collectively, “Corporate FinEdge Malaysia”, “we”, “us” or “our”) are committed to conducting business ethically, lawfully and with integrity.

This Whistleblowing Policy establishes a framework for the reporting, handling and investigation of genuine concerns relating to actual or suspected misconduct, improper conduct, unethical behaviour, corruption, fraud or other serious wrongdoing involving Corporate FinEdge Malaysia.

This Policy is intended to promote a culture of transparency, accountability and non-retaliation, and to support Corporate FinEdge Malaysia’s governance and compliance obligations, including its anti-bribery and anti-corruption framework.

2. Scope

This Policy applies to reports concerning Corporate FinEdge Malaysia and may be used by:

• directors, partners, principals and employees;
• interns, temporary staff, secondees and consultants;
• contractors, suppliers, service providers and business partners; and
• clients, counterparties or other persons who have a genuine concern relating to misconduct connected with Corporate FinEdge Malaysia.
  
  

3. Matters That May Be Reported

A report may be made under this Policy if the reporting person reasonably believes that there has been, is being, or is likely to be:

• bribery, corruption, kickbacks or facilitation payments;
• fraud, dishonesty, misappropriation or theft;
• conflict of interest or abuse of position;
• falsification of documents, records, accounts or reports;
• breach of law, regulation or internal policy;
• serious professional misconduct or unethical conduct;
• improper handling of client funds, confidential information or personal data;
• harassment, victimisation, retaliation or intimidation connected to a protected report; or
• any other serious improper conduct that may expose Corporate FinEdge Malaysia, its people, clients or stakeholders to legal, financial, reputational or regulatory risk.
  
  

This Policy is not intended to replace normal grievance channels for routine employment matters, commercial disputes or service complaints, unless such matters involve serious misconduct, illegality or retaliation.

4. Good Faith Reporting

A person making a report under this Policy should do so honestly, in good faith and on reasonable grounds.

The reporting person does not need to prove the allegation, but should provide as much factual detail as possible, including relevant dates, persons involved, supporting documents and circumstances known to them.

Knowingly making a false, malicious or frivolous report may itself be treated as misconduct.

5. Reporting Channels

Reports may be made through one or more of the following channels:

Whistleblowing Contact:

Corporate FinEdge Management Services

Email: cliff.goh@corporatefinedge.com

Telephone: +60 10-711 5229

Address: No. 15-02, Jalan Molek 1/42, Taman Molek, 81100 Johor Bahru, Johor, Malaysia

Corporate FinEdge Malaysia may designate alternative or additional reporting channels from time to time, including an independent reporting contact, external adviser or designated compliance person.

Where a concern involves the primary contact person, the report should be escalated to an alternative senior person, independent adviser or relevant authority where appropriate.

6. Confidentiality

Corporate FinEdge Malaysia will treat reports made under this Policy as confidential to the extent reasonably practicable and permitted by law.

Information relating to a report will only be disclosed on a need-to-know basis for the purpose of assessing, investigating, responding to or reporting the matter.

While anonymity may be permitted, reporting persons are encouraged to provide sufficient information and contact details so that clarification may be sought where necessary.

7. Protection Against Retaliation

Corporate FinEdge Malaysia prohibits retaliation against any person who makes a report in good faith, declines to participate in misconduct, or assists in an assessment or investigation under this Policy.

Retaliation may include dismissal, demotion, harassment, discrimination, victimisation, threats, intimidation, exclusion, adverse treatment or any other detrimental action taken because a person has made or assisted with a protected report.

Any retaliation against a reporting person or witness acting in good faith is itself a serious breach of this Policy.

8. Assessment and Investigation

All reports received under this Policy will be reviewed and assessed as soon as reasonably practicable.

Depending on the nature of the report, Corporate FinEdge Malaysia may:

• conduct a preliminary review;
• seek further information from the reporting person, where possible;
• appoint an internal or external person to investigate;
• take immediate risk-control or protective steps;
• refer the matter to legal advisers, auditors, regulators, law enforcement agencies or other appropriate authorities; or
• determine that the matter should instead be handled under another internal process.
  
  

The manner, scope and timing of any investigation will depend on the seriousness and nature of the allegations, available evidence, legal considerations and operational requirements.

9. Outcome and Action

Where appropriate, Corporate FinEdge Malaysia may take follow-up action including corrective measures, internal controls improvements, disciplinary action, contract termination, recovery steps, reporting to authorities or other remedial action.

The reporting person may be informed, where appropriate and lawful, that the matter has been reviewed or addressed, but detailed outcomes may not always be disclosed due to confidentiality, privacy, privilege or legal constraints.

10. No Immunity for Misconduct

A person who is involved in wrongdoing is not automatically protected from the consequences of their own conduct merely because they make a report.

However, voluntary disclosure and cooperation may be taken into account in determining the appropriate response, subject to applicable law and the facts of the case.

11. External Reporting

Nothing in this Policy prevents any person from making a report to the Malaysian Anti-Corruption Commission, the police, a regulator, a professional body or any other competent authority where appropriate.

This Policy is intended to support internal reporting and responsible escalation, but does not limit any legal right to report misconduct to an external authority.

12. Record Keeping and Data Handling

Corporate FinEdge Malaysia may maintain records relating to reports, assessments, investigations, findings and follow-up actions for legitimate governance, legal, audit, security and compliance purposes.

Any personal data collected in connection with a report will be handled in accordance with applicable law and, where relevant, Corporate FinEdge Malaysia’s Personal Data Protection Notice.

13. Review of Policy

This Policy may be reviewed, amended or updated from time to time to reflect changes in law, governance expectations, organisational structure or operational requirements.

14. Website Publication Version

This version may be used as a public-facing Whistleblowing Policy or reporting framework for publication on the corporatefinedge.my website.

Corporate FinEdge Malaysia may also maintain additional internal procedures, investigation protocols, escalation matrices and record-retention requirements separate from this published version.

15. Contact Details

Questions or reports relating to this Policy may be directed to:

Corporate FinEdge Management Services

No. 15-02, Jalan Molek 1/42,
Taman Molek, 81100 Johor Bahru, Johor, Malaysia

Tel: +60 10-711 5229

Email: cliff.goh@corporatefinedge.com

16. Bahasa Malaysia Version

If this Policy is made available in both English and Bahasa Malaysia, both versions are intended to assist understanding. In the event of inconsistency, the version adopted by Corporate FinEdge Malaysia for compliance purposes shall prevail to the extent required by applicable law.

Last updated: 30 April 2026