WHISTLE-BLOWING POLICY

7-Eleven is 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 largely through internal mechanisms.

This page provides the guideline, extracted from the Whistle-blowing Policy, for the reporting of a whistle-blowing complaint to the Management of 7-Eleven for action.

A) Whistle-blowing

Whistle-blowing is a form of Disclosure involving a Person (whistle-blower) who raises serious concerns at an early stage about risks of wrongful activities or reporting a wrongdoing. Any of thefollowing Persons (whistle-blower) can make a disclosure:

• 7-Eleven’s employees, including employees on contract terms, temporary or short-term employees and employees on secondment, where applicable;
• People performing services for 7-Eleven, including contractors and service providers; and
• Members of the public who are natural persons, not being incorporated or unincorporated bodies.

B) What to disclose

A disclosure may be made if it relates to one or more of the following wrongdoings by any personin the conduct of 7-Eleven’s business or affairs:

• Acceptance of favour;


• Corruption or fraud;


• Criminal offence;


• Misuse of 7-Eleven's funds or assets;


• Gross mismanagement within 7-Eleven;


• Serious financial irregularity or impropriety within 7-Eleven;


• Serious breach of 7-Eleven's Code of Conduct/Ethics;


• An act or omission which creates a substantial or specific danger to the lives, health, or safety of 7-Eleven’s employees, the public or the environment;


• Failure to comply within the provisions of other laws and regulations where the wrongdoer, knowingly disregards or does not comply with such provisions;


• Breach of customer confidentiality or privacy;


• Conflict of interest;


• Unauthorised use of confidential information;


• Knowingly directing or advising a person to commit any of the above wrongdoings; and


• Concealment of any of the above.

C) Acting in Good Faith

A whistle-blower shall 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 whistle-blower needs to demonstrate that he/she has reasonable grounds for the concerns. However, the whistle-blower is not expected to first obtain substantial evidence of proof beyond reasonable doubt when making a disclosure. If the whistle-blower knows as a matter of fact that there are reasonable grounds of suspicion that a wrongdoing is going to take place, such genuine concerns shall be raised at an early stage.

D) Protection from Retaliation

The Company does not permit retaliation of any kind against the whistle-blower for complaints submitted hereunder that are made in good faith. Any such reprisal may result in disciplinary action, including a warning or letter of reprimand, demotion, loss of merit increase, loss of bonus, suspension without pay, or termination of employment.

The whistle-blower’s identity shall be protected, i.e. kept confidential unless otherwise required by law or for the purpose of any proceedings by or against any company in the 7-Eleven Group.

E) How To Proceed

Disclosures pursuant to this Policy are to be made to the Head of Internal Audit in writing as follows:

• Mail: Head of Internal Audit
  7-Eleven Malaysia Sdn Bhd
  Level 3A, Podium Block, Plaza Berjaya
  No. 12, Jalan Imbi, 55100 Kuala Lumpur


• Email: whistleblower@7eleven.com.my

A disclosure shall include at least the following particulars:

• The name of the whistle-blower, name of his/her employer and designation, current address andcontact 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 its occurrence and theidentity of the alleged wrongdoer;
• Particulars of witnesses, if any; and
• Particulars or the production of documentary evidence, if any.

The whistle-blower may be asked to provide further clarification and information from time to time, for example, if an investigation is conducted.