Atlan Holdings Bhd (“AHB”) and its subsidiary companies (“the Group”) are committed to quality, honesty, openness and accountability. In line with this commitment, the Whistleblowing Policy (“the policy”) aims to provide an avenue for employees to raise genuine concerns, provided the whistleblower acts in good faith, and offer assurance that they will be protected from reprisals or victimisation for whistleblowing.

The policy is intended to conform to the guidance in the Code of Corporate Governance (the “Code”), which encourages employees to raise genuine concerns in confidence that discloses or demonstrates information that may evidence unethical or improper activity (“Protected Disclosures”).


  1. Promote standards of good corporate practices within the Group.
  2. Provision of appropriate avenues for employees to raise genuine concerns in the Group.
  3. Give employees the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.


The list of reportable incidents includes but not limited to the following:-

  • Incidents of fraud, corruption or bribery
  • Failure to comply with legal obligations
  • Failure to comply with the relevant financial reporting standards
  • Actions which endanger the health or safety of employees
  • Abuse of power or authority
  • Serious improper matters which may cause financial or non-financial loss to the Group or damage the Group’s reputation
  • Actions which are intended to conceal any of the above


If the whistleblower raises a genuine concern under this Policy, the person concerned will not be at risk of losing his or her job or suffering from retribution or harassment as a result. The whistleblower must act in good faith in raising a concern. The Group will not condone frivolous, mischievous or malicious allegations. Whistleblower (s) making such allegations will face disciplinary action, including possible legal consequences. The identity of the Whistleblower shall be kept confidential to the extent possible and permitted under law.

Protection under this Policy would not mean protection from disciplinary action arising out of false or bogus allegations made by a Whistleblower knowing it to be false or bogus or with a mala fide intention.

A whistleblower who makes a report that is not done in good faith or found to be mala fide or malicious, is subject to discipline, including termination of the Board or employee relationship, or other legal means to protect the reputation of the organization and members of its Board and staff.


If the whistleblower wishes to raise a concern in confidence under this Policy, the Group shall endeavour to keep his or her identity confidential. The Group WILL NOT attend to any concern if the whistleblower who raises the concern remains anonymous.


The Group assures that any information provided will be investigated but consideration will be given to these factors:-

Protected Disclosures should be factual and not speculative or in the nature of a conclusion, and should contain as much specific information as possible to allow for proper assessment of the nature and extent of the concern.

The Group requires the whistleblower to set out the details of the background, history of events and the reasons for the concern, including the identity of the alleged person involved. This will assist the Group to consider appropriate actions including initiating further investigation to the concern raised.

The Whistleblower’s role is that of a reporting party with reliable information. They are not required or expected to act as investigators or finders of facts, nor would they determine the appropriate corrective or remedial action that may be warranted in a given case. Whistleblowers should not act on their own in conducting any investigative activities, nor do they have a right to participate in any investigative activities other than as requested by the Chairman of the Audit and Risk Management Committee or the Investigators.


The Group assures that any information provided will be investigated but consideration will be given to these factors:-

  • Severity of the concern raised by the whistleblower
  • Reliability of the concern provided by the whistleblower
  • Credibility of the information provided by the whistleblower

Should the investigation requires further information or cooperation from the whistleblower, the whistleblower must cooperate fully in the investigation.


The Company reserves its rights to amend or modify this Policy, in whole or in part, at any time without assigning any reason whatsoever. Modification may be necessary, among other reasons, to maintain compliance with laws and regulation and / or accommodate organizational changes within the Company or Group. However, no such amendment or modification will be binding on the Employees unless the same is circulated to the employees in writing or electronically.