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Objective

The Ethics / Corporate Responsibility Unit (ECRU) is established to implement whistleblowing (ie. public interest disclosure) procedures in GD Express Carrier Bhd & its group of companies (GDEX).

Scope Of Work

Line of Responsibility

Report directly to Chairman of AC.

General Principles

ECRU will ensure the following general principles will apply in GDEX:

Evaluation

GDEX whistleblowing procedure will be part of the annual cycle of monitoring compliance related to Corporate Governance. Annually ECRU will present an evaluation report of its activities and findings to AC of the Board of Directors.

ANNEX I

GDEX WHISTLEBLOWING POLICY & PROCEDURES

Objective

The objective of GDEX Whistleblowing Policy & Procedures (WBPP) is to ensure that each and every employee of GDEX, through understanding the WBPP, will come forward to express his or her concerns about a (suspected) malpractice, without fear of punishment or unfair treatment.

This WBPP will guide GDEX employee on how to raise such concerns.

Definition

Whistleblowing is a term used for what is legally known as Public Disclosure Policy, which is when an employee discloses information about malpractice or wrongdoing they discover occurring in GDEX.

What To Report

The malpractices or wrongdoings that an employee should report under WBPP are:

The procedures under WBPP should NOT be used for:

Sometimes it is not clear whether a particular action falls under the malpractices described above. In such cases, GDEX would prefer that the employee report his or her concerns in good faith rather than to keep to himself or herself.

Importance Of WBPP To GDEX

Role Of Every GDEX Employee

Reporting Rules & Procedures

Conclusion

The Board of Directors of GDEX is strongly committed in having a strong whistleblowing culture and will, through the ECRU, regularly assess the company internal whistleblowing system.

GDEX employees are encouraged to provide suggestions and feedback on improving the company whistleblowing system.

GDEX whistleblowing procedure will be part of the annual cycle of monitoring compliance related to Corporate Governance. Annually ERCU will present an evaluation report of its activities and findings to the Audit Committee of the Board of Directors without naming the reporting employees as guaranteed under the company WBPP.