Whistleblowing Mechanism

The Company has established secure complaint-handling and whistleblowing channels, with a dedicated Whistleblowing & Investigation Function responsible for managing the mechanism. (Click here to see the Whistleblowing & Investigation Function Structure) which their responsibilities include complaint intake, verification, investigation, and reporting of findings, while ensuring the protection of whistleblowers and all related parties. The scope of complaints covers any breaches of applicable laws and regulations, the Principles of Corporate Governance, the Company’s Code of Conduct, and internal policies, as well as acts of corruption, fraud, embezzlement, or misuse of authority for unlawful personal gain. Whistleblowers and complainants may submit reports confidentially and anonymously, with the option to use an independent third-party operated channel. If identity is disclosed, investigations can be conducted more effectively and outcomes communicated back to the reporter. In all cases, information provided is kept strictly confidential, and access is limited to authorized personnel only.

The Company enforces a strict zero-tolerance policy for retaliation, ensuring that whistleblowers and complainants are protected from any adverse consequences, such as changes to job duties, harassment, or unfair treatment. Any improper disclosure of confidential information will result in disciplinary or legal action. Conversely, deliberately false or malicious reporting constitutes a violation of the Code of Conduct and may result in disciplinary measures or legal proceedings.

Investigation Process

Upon receiving a report, the Company ensures that each case is handled independently, fairly, and transparently. Reports are assessed, investigated, and monitored to resolution in a comprehensive and equitable manner. Progress is tracked to ensure timely and effective handling, and outcomes are reported in line with confidentiality requirements.

Training & Awareness

The Company also provides training and awareness activities on the whistleblowing mechanism to ensure employees understand how to use the reporting channels responsibly and securely.

Whistleblowing Channels

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Service Complaint

Makro

Our customers are able to report any complaints relating to our products and services

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Service Complaint

Lotus's

Our customers are able to report any complaints relating to our products and services

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Whistleblowing Guidance

The Company conducts mandatory annual whistleblowing training for all employees to reinforce our commitment to maintaining the highest standards of ethical conduct and encouraging a speak-up culture. We also provide simplified training on the use of reporting channels for suppliers and external stakeholders on our website, enabling them to report concerns regarding unethical practices or misconduct. The Company actively encourages all stakeholders to utilize these channels, emphasizing that reports are handled with strict confidentiality and without fear of retaliation.