Whistleblowing Policy

CCPay Whistle blowing Policy
At CCPay, we expect our employees to conduct themselves with a high standard of professionalism
and ethics in the conduct of our business and professional activities. As part of good corporate
governance, CCPay has established a whistle blowing policy that sets out avenues for legitimate
concerns to be objectively investigated and addressed. Individuals will be able to raise concerns about
illegal, unethical or questionable practices in confidence and without the risk of reprisal.

1. What is whistle blowing?
The whistle blowing may relate to any information pertaining to wrongdoings, malpractices, and/or
irregularities as per the following list which is not exhaustive:

• Any unlawful act, whether criminal or breach in civil law;
• Breach of policies and/ or procedures;
  Fraud, corruption, misappropriation or dishonesty;
• Actions which can cause physical danger/ harm to another person and/or can give rise to risk
  of damage to properties/ assets;
• Forgery or alteration of any documents belonging to the company, customers, another financial institution, or agents of the company;
• Profiteering as a result of insider knowledge;
• Misuse of position or information;
• Sexual harassment and
• Any other similar or related irregularities shall be reported.

2. Who should raise a concern?
Anyone has the right to whistle blow. This whistle blowing policy is applicable to all employees, suppliers,
vendors, associated stakeholders and the customers of CCPay. Whilst we do not expect absolute proof
of wrong-doing that you report, you will need to provide the reasons or basis for your concern. You can
raise your concern with us if you reasonably believe that the information and allegation are substantially
true. In addition, you must also make the disclosure in good faith and ensure that the disclosure is not
for personal gain or motivated by ill intention.

3. How to raise a concern?
We take whistle blowing seriously and your concern matters to us, so we would like to hear from you if
any of your disclosure is related to improper practices occurring within CCPay. Please email your
concern to [email protected] and we will investigate the matter.
To facilitate an investigation into the alleged wrongdoing, where possible and applicable, the following
information should be included when making a disclosure:
a) Brief description of the misconduct;

b) The date and location of the incidence;

c) The identity of the wrongdoer;

d) Particulars of witnesses, if any;

e) Supporting evidence and/or documents;

f) Other details deemed to be useful to facilitate screening and action to be carried out.

We at CCPay recognize that the provision of anonymity to any individual/employee who willingly comes
forward to report is a key to encouraging such reporting. Accordingly, to prevent false malicious
reporting, poison letters and abuse of the reporting channel, all whistleblowers are highly encouraged
to identify themselves and provide contact information in their reports which will be useful for the
following purposes:
a) To enable the independent investigation panel to verify each report and to obtain further
information, if required;
b) To facilitate any further investigations by auditors or the authorities where the identity of
the informer is required by law; and
c) To facilitate the communication of results of investigation to the whistleblower.

In view of the above, the whistleblower is to disclose his/her personal details to enable the relevant
parties conducting the investigation to contact the Whistleblower for further information:
a) Name; and
b) Contact details – email address and/or telephone number.

4. How does CCPay handle the information provided by you?
After receiving the report of any alleged wrong-doing, it will be investigated by our Compliance
Department and reporting to an Independent Board of Director.
If the outcome results in a proven case of wrongdoing/malpractice and confirms the allegations,
disciplinary action shall be instituted against the related employees in accordance with the company’s
policy. CCPay commits to ensure that all disclosed information, including the identity of the
whistleblower shall be treated with strictest confidence and will only reveal them on a “need to know”
basis for the purposes of investigating the reports.
The Independent Board of Director will have the ultimate discretion whether to reveal the identity of the
“whistleblower”. However, there may be certain circumstances where the identity of the whistleblower
may need to be revealed (e.g. requirement to testify in court). If such a situation arises, CCPay shall
discuss and seek consent with the whistleblower prior to proceeding with the case.

5. Outcomes of the investigation
The whistleblower will be updated via email on the status of their report and reassurance on follow-up
action, provided that, the detail of the whistleblower is complete.