a) Board Charter
b) Terms of Reference of
    Audit Committee

c) Terms of Reference of
    Nomination Committee

d) Terms of Reference of
  Remuneration Committee

e) Code of Conduct
    And Ethics

f) Whistleblowing Policies
    and Procedures

g) Anti-Corruption Policies
    and Procedures

h) Shareholder
    Communication Policy

i) Remuneration Policy
   and Procedures

j) Policies and Procedures
   to Assess the Suitability
   and Independence of
   External Auditors

k) Extract Minutes of
   General Meetings

Whistleblowing Policies and Procedures


Paos Holdings Berhad ("PAOS") is committed to high standards of ethical, moral and legal business conduct and observes zero tolerance towards malpractice, impropriety, statutory non-compliance or wrongdoing by staffs. In line with this commitment, this policy aims to provide an avenue for all employees of PAOS and its subsidiaries (“Group”) to raise concerns and reassurance that they will be protected from reprisal or victimization for whistle blowing.



This policy is designed to facilitate all employees of the Group to report or disclose through established channels, concerns about improper conduct or misconduct, or failure to comply with regulatory requirements that is taking place/has taken place/ may take place in the future.

The types of improper conduct shall include, but not limited to the following:

  • Fraud (embezzlement, theft and misappropriation) of PAOS Group’s funds or assets;
  • Bribery, corruption or money laundering;
  • Criminal breach of trust, abuse of power and position or blackmail;
  • Improprieties and irregularities in accounting and financial reporting;
  • Improper or unethical conduct or behaviour within the meaning of PAOS Group’s Code of Business Conduct & Ethics or other PAOS Group’s policies;
  • Unauthorized disclosure or use of confidential information of PAOS Group;
  • Conflict of interest within the meaning of PAOS Group’s conflict of interest policy;
  • Misuse of PAOS Group’s properties, assets or resources;
  • Non-compliance with PAOS Group’s policies and procedures or breach of internal control;
  • Acts or omissions which are deemed to be against the interests of the PAOS Group;
  • Non-compliance with laws, regulations, requirements of statutory bodies or public policies;
  • Danger to health and safety of any employee of PAOS Group or any other individual;
  • Damage to the environment;
  • Sexual harassment;
  • An accomplice to or deliberate concealment of any or a combination of the above matters or other acts of wrongdoing;
  • Unethical behaviour; and
  • Other illegal acts and malpractices.


The Policy is encouraged employees to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be explored appropriately but consideration will be given to:

  • The seriousness of the issue raised
  • The credibility of the concern; and
  • The likelihood of confirming the allegation from attributable sources.


The Company shall treat all reports or disclosures as sensitive and will only reveal information on a “need to know” basis or if required by law, court or authority. The identity and particulars of the whistle blower shall also be kept private and confidential.


This policy provide assurance that the whistleblower will not be at risk of losing job or suffer any form of retribution or harassment provided that the disclosure is made in good faith even if the investigation later reveals that the whistleblower is mistaken as to the facts and rules and procedures involved. The policy does not, however extend to anyone who wilfully or maliciously raises a concern, knowingly or believing the information is false or true.

All concerns or irregularities raised will be treated with privacy and confidentiality and every effort will be made to ensure that confidentiality is maintained throughout the whistleblowing process. Concerns must be reported in writing and should be factual and not speculative or in the nature of a conclusion and should contain as much specific information as possible so as to allow for a proper assessment of the nature and extent of the concern.

All employees and third parties are to disclose any concern in a confidential manner. Third parties should report to the Group Chairman. Employees should report to their immediate superior where possible. If for any reason, it is believed that this is not possible or appropriate, employees shall report to the Group Chairman:-

Name : Ms Felicia Lim
Email : felicia@paos.com.my
Mail : Marked Strictly Confidential
c/o Paos Holdings Berhad
65, Persiaran Selangor,
Section 15, 40200 Shah Alam,
Selangor Darul Ehsan.
Attention : Group Chairman

In the case where reporting to management is a concern, then the report should be made to the Chairman of the Audit Committee:-

Name : Mr Lim Poh Seong
Email : pslim@paos.com.my
Mail : Marked Strictly Confidential
c/o Paos Holdings Berhad
65, Persiaran Selangor,
Section 15, 40200 Shah Alam,
Selangor Darul Ehsan.
Attention : Chairman – Audit Committee



  • All reports will be investigated promptly by the person receiving the report. If required, he can obtain assistance from other resources within the Group. The progress of investigation will be reported to the Audit Committee no later than at the next scheduled meeting.
  • Upon completion of investigation, appropriate course of action will be recommended to the Audit Committee for their deliberation. Decision taken by the Audit Committee will be implemented immediately.
  • Where possible, steps will also be implemented to prevent situation arising.

If for any reason, the person making the report is not satisfied with the way his report had been dealt with, he can escalate his report to the Chairman of Audit Committee, Mr Lim Poh Seong.

Chairman of Audit Committee will deliberate the report with his committee members and decide on the appropriate course of action.