Whistleblowing System

Whistleblowing System

MBMA implements MDKA’s Whistleblowing System as a platform for all stakeholders, including both internal and external parties, to report legal violations or breaches of internal company procedures that includes the company’s Code of Ethics, Anti-Corruption and Bribery Policy, Anti-Money Laundering Policy, Environmental Health and Safety Policy, Employment Policy, Human Rights Policy, and other relevant regulations.

The Company is committed to receiving any complaints/reports of violations/suspected violations by providing the Whistleblowing System through a tool that is managed independently by a third party selected by the Company hereinafter referred to as the ‘Consultant’.

Every MBMA Personnel or other parties is required to report if they know of a violations/suspected violations by using the predetermined tool. The report must be made based on goodwill, fairness, honesty and respect, through a reporting tool as follows:

• Speak Up Website: https://mcg.whispli.com/SpeakUp
• Phone Number and WhatsApp: 0812 5000 1018

This Whistleblowing System adopts principles to anti-retaliation, confidentiality, and anonymity.

Principles of anti-retaliation:

1. Retaliation in the form of termination, demotion, suspension, harassment, or other forms of discrimination will not be tolerated when questions and/or reports of violations/alleged violations are made in good faith.
2. No specific action will be taken if the violation/alleged violation is not substantiated.
3. If there is any party or individual found to be retaliating against others, disciplinary action will be taken.

Principles of confidentiality:

1. Every reported issue will be processed and handled confidentially, impartially, professionally, objectively, neutrally, and with caution.
2. The confidentiality of every inquiry and report of violations/alleged violations will be maintained according to the reporter’s request. The reporter has the right and option to disclose their identity or remain anonymous; however, in some cases, there may be limitations on what can be achieved: a thorough investigation can be challenging if the provided information cannot be tested or verified, and investigators may not be able to obtain further information from the reporter.
3. For highly serious matters (e.g., those with the potential involvement of legal processes), MBMA has a decision that is not subject to challenge by the reporter in its resolution.

Principles of anonymity:

1. Inquiries and reports of violations/alleged violations submitted anonymously will, as far as possible, be processed using the available information. However, it is not ruled out that confirmation with relevant sources may be necessary.
2. Any violation/alleged violation reported anonymously will be more difficult to investigate and resolve. Therefore, it is strongly encouraged, whenever possible, to provide the identity of the reporter.

The Consultant will confirm the receipt of the report as referred and conducts an initial assessment of the report and submit it to an official appointed by the Company. Officials who receive reports are responsible for paying attention to and following up on issues that are submitted to them.

The Company will take firm action against any violation through the provision of sanctions. Sanctions will be given to every MBMA Personnel who is proven to have committed a violation as an effort to uphold the Company’s values.