Whistleblower policy

AMWAY (MALAYSIA) HOLDINGS BERHAD
WHISTLEBLOWER POLICY
Whistle blowing is a form of disclosure. It involves a Person, i.e. the whistleblower raising serious concerns at an early stage about risks of wrongful activities or reporting a wrongdoing. Amway (Malaysia) Holdings Berhad ("Amway" or the "Company") and its subsidiaries ("AMHB" or the "Group") are committed to the values of transparency, integrity, impartiality and accountability in the conduct of its business and affairs. It expects wrongdoings such as fraud, corruption, serious financial impropriety and gross mismanagement to be reported and facilitates this through internal mechanisms. AMHB expects wrongdoings such as fraud, corruption, serious financial impropriety and gross mismanagement to be reported, and it facilitates this through internal mechanisms. The Board of Amway is desirous of establishing procedures for: (a) the receipt, retention, and treatment of complaints received by the Group regarding financial, internal accounting controls, or auditing matters; (b) submissions by employees of the Group, on a confidential and anonymous basis, and in good faith concerning questionable financial or auditing matters, as this provides additional protection to employees who come forward with information about actual or potential corporate fraud involving their employer; (c) any complaints that it has received regarding financial statement disclosures, financial, internal accounting or disclosure controls or auditing matters, disclosure violations or violations of the Group's adopted policies; and (d) other wrongful activities or wrongdoings. This Policy provides an alternative route for Persons of AMHB to raise concerns if the usual lines of communication are not available. Nothing in this Policy shall interfere with other established operational policies and processes. For the purpose of this Policy, ‘Person' includes any person who is employed by the Group, as well as those described in the "Who Can Disclose" section on the following page.

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Scope of Policy
The purpose and objectives of this Policy are:  To facilitate the making of a disclosure as early as possible and in a responsible manner by putting into place internal procedures;  To address a disclosure in an appropriate and timely manner. When disclosure matters are addressed, they may be prioritised according to the nature or gravity of the allegedwrongdoing(s) or reported risk(s) and the magnitude of the repercussions;  To protect a whistleblower from reprisal as a direct consequence of making a disclosure and to safeguard such person's confidentiality; and  To treat both the whistleblower and alleged wrongdoer fairly. The whistleblower will be informed of the status of his/ her disclosure. The alleged wrongdoer will be informed of theallegations (though not necessarily at the start of the investigation) and given an opportunityto respond to the allegations. The identities and personal information of the whistleblowerand the alleged wrongdoer will be revealed only to persons involved in investigations or anyother processes on a "need-to-know" basis only.
Monitoring and Review
In general, all disclosures pursuant in this Policy are to be made to the Prescribed Officer who is an officer of AMHB designated by the Managing Director ("MD") from time to time. At this juncture, the Legal Counsel (or his/ her equivalent) shall be the Prescribed Officer. The Prescribed Officer is responsible for ensuring compliance with this Policy and will prepare a report consisting of confidential complaints which include the following information:  Number of complaints;  Types of complaints;  Nature of process or resolution; and  Whether the allegation was founded or not.
This report will be used for statistical purposes only and presented to the Board of Directors of Amway on an annual basis. The Board will be apprised of disclosure matters which are serious in nature or of grave repercussions.

AMWAY (MALAYSIA) HOLDINGS BERHAD
This Policy may be reviewed and amended from time to time, as and when necessary, to ensure its relevance and effectiveness in keeping with AMHB's changing business environment or administrative or operational needs. Reporting Procedures
This Policy is intended to complement the normal channels of communication and reporting lines within AMHB. Persons should first consult or raise their concerns with their immediate supervisors or heads or, when necessary, the MD. However, if their complaints or concerns remain unresolved, this Policy provides a facility for such Persons to make formal disclosures to be escalated to the relevant channel detailed on the Contact Information section at the end of this Policy. 1) Who Can Disclose Any of the following Persons can make a disclosure: AMHB's employees, including employees on contract terms, temporary or short-termemployees and employees on secondment, where applicable; People performing services for AMHB, including contractors and service providers; Members of the public who are natural persons, not being incorporated or unincorporatedbodies.
2) What To Disclose A disclosure may be made if it relates to one or more of the following wrongdoings by any person in the conduct of AMHB's business or affairs:  acceptance of favour; corruption or fraud; criminal offence; misuse of AMHB's funds or assets; gross mismanagement within AMHB; serious financial irregularity or impropriety within AMHB; serious breach of AMHB's Code of Ethics; an act or omission which creates a substantial or specific danger to the lives, health, or safety of AMHB's employees, the public or the environment;  failure to comply within the provisions of other Acts of Parliament where the wrongdoer, knowingly, disregards or does not comply with such provisions; and  knowingly directing or advising a person to commit any of the above wrongdoings.

AMWAY (MALAYSIA) HOLDINGS BERHAD
This Policy excludes grievances, complaints or concerns about:  matters which are trivial or frivolous or malicious or vexatious in nature or motivated by personal agenda or ill will;  matters pending or determined through AMHB's disciplinary proceedings; and matters pending or determined through any tribunal or authority or court, arbitration or other similar proceedings.
A wrongdoing may occur in the course of AMHB's business or affairs or at any workplace i.e. any related workplace to AMHB's business or affairs, for example, on AMHB's premises, at an event organised by AMHB, or during a conference attended by AMHB's employees in the course of his/ her work. If a Person is unsure whether a particular act or omission constitutes a wrongdoing under this Policy, he/ she is encouraged to seek advice or guidance from his/ her immediate superior or head or, when necessary, the MD. 3) When To Disclose A whistleblower should come forward with any information or document that he or she, in good faith, reasonably believes and discloses a wrongdoing, which is likely to happen, is being committed or has been committed. The whistleblower needs to demonstrate that he/ she has reasonable grounds for the concerns. However, he/ she is not expected to first obtain substantial evidence of proof beyond reasonable doubt when making a disclosure. If he/ she knows as a matter of fact that there are serious risks that a wrongdoing is going to take place, such genuine concerns should be raised at that early stage. Disclosure should be made within one (1) month of coming upon such information or document. Delaying the disclosure may be detrimental to the whistleblower as well as any investigation, and makes it harder for AMHB to address and resolve the concerns. 4) How To Proceed Generally, all disclosures pursuant to this Policy are to be made to the Prescribed Officer except in the circumstances specified below. The Prescribed Officer is currently the Legal Counsel. a) A disclosure can be made in writing, orally or via electronic mail ("email").
b) The Prescribed Officer will commit to writing a disclosure made verbally and the whistleblower is to confirm the written statements. As far as reasonably practicable, suchdisclosure will be made in a private room within AMHB's premises.

AMWAY (MALAYSIA) HOLDINGS BERHAD
c) A disclosure shall include at least the following particulars:  if the whistleblower is an employee of AMHB, his/ her name, designation, current address and contact numbers; or  if the whistleblower is not an employee of AMHB, his/ her name, name of employer and designation, current address and contact numbers;  basis or reasons for his/ her concerns including as many details of the wrongdoing as reasonably possible, for instance, its nature, the date, time, and place of itsoccurrence and the identity of the alleged wrongdoer;  particulars of witnesses, if any; and particulars or production of documentary evidence, if any.
The whistleblower may be asked to provide further clarifications and information from time to time, for example, if an investigation is conducted. d) The Prescribed Officer will screen and assess the disclosure to determine whether it is related to a wrongdoing or excluded from the scope of this Policy, and will preparegeneral recommendations to the deciding authority. This initial process should not takemore than two (2) weeks from the day the Prescribed Officer receives the disclosure. Itmay be completed immediately if the wrongdoing is capable of causing irreparable harmto AMHB.
e) A disclosure can be made directly to the Audit Committee Chairman in either of the following circumstances:  where the wrongdoing involves the Prescribed Officer; or where the wrongdoing does not involve the Prescribed Officer but the whistleblower, in good faith, reasonably believes that there will be a cover-up orthat the Prescribed Officer is personally conflicted (for instance, the PrescribedOfficer is a close friend of the alleged wrongdoer); and  in either circumstance, there will be no referral to a higher authority. The Audit Committee ("AC") Chairman has the authority to make the final decisionsincluding but not limited to any of those mentioned below in (f). The ACChairman may designate any persons, other than the Prescribed Officer, fromwithin or without AMHB to conduct any investigation or to carry out any otherprocess pursuant to this Policy (for instance, any meeting or an internal audit).
Following Paragraph (d) above, the disclosure together with the generalrecommendations will be referred by the Prescribed Officer to the AC Chairman who hasthe authority to make final decisions including but not limited to any of the following:  rejection of the disclosure; directing the concerns or any part thereof for consideration under other internal procedures or disciplinary procedures, if appropriate and applicable;  resolution without recourse to an investigation; directing investigations of the Disclosure and any persons involved or implicated;

AMWAY (MALAYSIA) HOLDINGS BERHAD
 Suspending the alleged wrongdoer or any other implicated person from work to facilitate any fact-finding or to avoid any employee's exposure to a threat orharm;  Designating the Prescribed Officer or any other persons from within or without AMHB to conduct any investigation or to carry out any other process pursuant tothis Policy (for instance, any meeting or an internal audit);  Obtaining any other assistance (for instance, external auditors or legal advice);  Referral to the police or any other appropriate enforcement authority.
g) If the disclosure involves the MD or a Director or any other persons, following Paragraph (e) above, the disclosure will be referred directly to the AC Chairman who will then be
responsible for the investigation and recommendation to the Board of Directors of
AMHB. The Board of Directors has the authority to make final decisions. All such
concerns shall be set forth in writing and forwarded in a sealed envelope to the Chairman
of the Audit Committee, in care of the Company Secretary, in an envelope labeled with a
legend such as "To be opened by the Audit Committee only, in the presence of the
Company Secretary. Being submitted pursuant to the "whistleblower policy" adopted
by the Audit Committee."
If the Person would like to discuss any matter with the AC, the Person should indicate this in the submission and include a telephone number at which he or she might be contacted if the AC deems it appropriate. Any such envelopes received by the Company Secretary shall be forwarded promptly and unopened to the Chairman of the AC. Being Informed and Having The Opportunity to Be Heard
The whistleblower will be informed of the status of his/ her disclosure matter as far as reasonably practicable. The whistleblower and the alleged wrongdoer are expected to give his/ her full cooperation in any investigation or any other process carried out pursuant to this Policy. The alleged wrongdoer may be asked to attend a meeting to discuss the allegations and must take all reasonable steps to attend the meeting. He/ she will be given an opportunity to answer the allegations at the meeting, and his/ her own answers will be recorded in the minutes of the meeting. The meeting may be adjourned for AMHB to obtain any advice or proceed with further investigations. A meeting may not necessarily be held within the early stages of an investigation. In the event the whistleblower is implicated or discovered to be or have been involved in any wrongdoing, he/ she may also be investigated so as to complete the fact-finding process. An investigation is not and shall not be treated as a reprisal against the whistleblower. It is to facilitate decision making. The whistleblower may then be asked to attend a meeting to discuss the allegations and must take all reasonable steps to attend that meeting. He/ she will be given an opportunity to answer the allegations at that meeting, and his/ her own answers will be recorded in the minutes of that meeting. That meeting may be adjourned for AMHB to obtain further advice or proceed with further investigations.

AMWAY (MALAYSIA) HOLDINGS BERHAD
The whistleblower, and if applicable, the alleged wrongdoer will be notified in writing or the decision on the wrongdoing (e.g. whether the wrongdoing occurred or not; or whether the alleged wrongdoer is guilty or not), and the basis thereof. Handling/ Discussion of an Investigation
1) No information concerning the status of an investigation will be given out. The proper response to any inquiry is: "I am not at liberty to discuss this matter".
2) Under no circumstances should any reference be made to "the allegation," "the crime," "the fraud," "the forgery," "the misappropriation," or any other specific reference.
3) The reporting individual should be informed of the following:  Do not contact the suspected individual in an effort to determine facts or demand  Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Prescribed Officer.
Consequences of Wrongdoing or Wrongful Disclosure
If the Person (i.e. the whistleblower) of AMHB has, or is found to have:  committed a wrongdoing; taken serious risks which would likely cause a wrongdoing to be committed; made a disclosure not in accordance with the requirements of this Policy (for instance, dishonest, mischievous or malicious complaints); or  participated or assisted in any process pursuant to this Policy otherwise than in good faith, the corrective actions to be taken against that Person will be determined by the MD or, if so delegated by the MD, the Senior Management, which may include, disciplinary measures, formal warning or reprimand, demotion, suspension or termination of employment or services with AMHB or monetary or other forms of punishment. Protection under this Policy
Upon making a disclosure in good faith, based on reasonable grounds and in accordance with the procedure pursuant to this Policy:  the whistleblower will be protected from reprisal within AMHB as a direct consequence of his/ her disclosure; and  the whistleblower's identity will be protected i.e. kept confidential unless otherwise required by law or for purposes of any proceedings by or against AMHB.

AMWAY (MALAYSIA) HOLDINGS BERHAD
The identities and personal information of the whistleblower and the alleged wrongdoer may be revealed to persons involved in investigations or any other processes on a "need-to-know" basis. The Prescribed Officer shall retain as a part of the records any such complaints or concerns for a period of no less than seven (7) years. A reprisal means disciplinary actions, which may include, alone or in combination, a warning or letter of reprimand, demotion, loss of merit increase, loss of bonus, suspension without pay or termination of employment. If the Person of AMHB, in good faith, reasonably believes he/ she is being subjected to harassment, victimisation or a reprisal as a direct consequence of having made a disclosure under this Policy, he/ she may consult the Prescribed Officer in confidence. Essentially, the complaint will be processed in a similar manner as a whistle-blowing disclosure and is subject to similar requirements. The Company does not permit retaliation of any kind against the whistleblower for complaints submitted hereunder that are made in good faith. Any such reprisal will in itself be considered a serious breach of this Policy. AMWAY (MALAYSIA) HOLDINGS BERHAD
Contact Information
Company Secretary
Tricor Corporate Services Sdn Bhd Unit 30-01, Level 30, Tower A Vertical Business Suite Avenue 3, Bangsar South No. 8, Jalan Kerinchi, 59200 Kuala Lumpur Phone : 03-2783 9130 Fax : 03-2783 9111Email Audit Committee Chairman
Dato' Ab. Halim Mohyiddin c/o Tricor Corporate Services Sdn Bhd Unit 30-01, Level 30, Tower A Vertical Business Suite Avenue 3, Bangsar South No. 8, Jalan Kerinchi, 59200 Kuala Lumpur Phone : 03-2783 9130 Fax : 03-2783 9111 Email : [email protected] Vice President &
Scott Russell Balfour Deputy General Counsel
- Lead Regional Counsel Asia
7575 Fulton Street East & Greater China Region
Ada, Michigan 49355 001-616-787-6714 001-616-787-5624 Vice President aDeputy General Counsel-Lead Regional Counsel Asia and Greater

Source: http://www.amway.com.bn/en/ResourceCenterDocuments/Visitor/MY_AMWAY_WhistleBlowerPolicy.pdf