Corporate Policies

This whistleblowing policy provides a structured arrangement and guidance for the suspicion, reporting, and investigation of fraudulent practices or misconduct within the Group.

The objectives are:

• Promote standards for good financial and corporate practices and deter wrongdoing.
• To provide a channel of communication to report suspected fraudulent activities, and guide them on actions to address their concerns effectively; and
• Address reportable incidents and to provide the process for investigation and management reporting.

This policy deals with concerns on improprieties and wrongdoings:

• Affecting the financial position of the Group;
• Relating to the honesty and integrity of the Group’s dealings or its employees/directors;
• Including, but not limited to:
  • Conflicts of interest - An employee or officer should always act in the best interest of the Group. A “conflict of interest” occurs when an individual’s personal interests interfere or appears to interfere with the interests of the Group.
  • Confidentiality. Employees and directors must maintain the confidentiality of information entrusted to them by the Group or its customers, except when disclosure is authorized or legally mandated.
  • Fair dealing. Each employee and director should endeavor to deal fairly with the Group’s customers, suppliers, competitors and employees. None should take unfair advantage of anyone through dishonesty, misrepresentation of material facts or any other unfair practice.
  • Protection and proper use of the Group’s assets. All employees and officers should protect the Group’s assets and ensure their efficient use for legitimate business purposes.
  • Compliance with laws, rules and regulations (including insider trading laws). We actively promote compliance with laws, rules and regulations.
  • Unethical behavior. We actively promote ethical behavior and encourage employees to report any misconduct in this regard.

This policy applies to employees, vendors/contractors, consultants, and/or any other parties whom the Group has a business relationship with. Employees of the Group are responsible to highlight any suspicion of fraudulent practices and inappropriate activities within the Group and bring them immediately to the attention of the Audit Committee.

This policy encompasses various concerns, including:

• Financial impropriety (theft, embezzlement, corruption, misuse of assets/resources)
• Legal breaches (criminal conduct, regulatory non-compliance)
• Policy violations (non-adherence to company policies/procedures)
• Accounting/auditing irregularities (internal controls, financial reporting)
• Conflict of interest (undisclosed interests/material gain)
• Auditor/accountant misconduct (misleading/deceptive practices)
• Workplace abuse (bullying, harassment, abuse of power)
• Sexual harassment (physical/verbal/visual)
• Fraudulent activities (theft, bribery, embezzlement)
• Concealment of malpractice/misconduct
• Misleading public bodies (providing false information)

This list isn't exhaustive, but it highlights key areas covered by the policy.

In line with our commitment to keep all concerns confidential, dedicated communication channels have been established. Whistleblowers may choose to use any of these communication channels to communicate with the committee of the Audit Committee as follows:

All of the above communication channels are secure and available to all employees, volunteers, members, suppliers, customers, partners, and any other parties with a relationship with the Group. Upon receiving the concern (whether by physical mail or email), the audit committee will determine the next course of action.

When making a report, the whistleblower should as far as practicably include the following information:

• Date, time and place of the actions/ transactions.
• Identity and particulars of the parties involved.
• Circumstances leading to the improprieties.
• Reason(s) for the concern.
• Any other relevant information or documentation that would assist in evaluating the report / incident.

Whistleblowers making any such reports should ensure that they do so in good faith and the best interest of the Group and not with any malicious intent. Whistleblowers may be the subject of disciplinary or other legal action if the reports or allegations are malicious, frivolous, or to cause anger, irritation, or distress.

Employees should not use the avenues provided by this policy to deal with any matters that are covered by other procedures even if serious or sensitive such as:

• Complaints about the terms or other aspects of your employment
• Customers’ complaints about our products and services

The Audit Committee, will be responsible for the administration of this policy, which will be reviewed annually by the Board of Directors. By providing a secure, confidential, and anonymous reporting mechanism, we aim to promote a culture of transparency, accountability, and integrity within our company.

At Allied Container Group, we prioritize confidentiality and protection for whistleblowers. All reports are handled discreetly, and whistleblowers' identities are safeguarded unless disclosure is legally required. We strictly prohibit retaliation, harassment, or victimization against whistleblowers, and any such incidents will be treated as serious misconduct. Whistleblowers will receive support and guidance throughout the process. Anonymous reporting options are also available, and we will maintain anonymity where possible while ensuring thorough and impartial investigations.