Whistleblower Policy Statement

At Zavarco PLC, we are committed to upholding the highest standards of integrity, transparency, and ethical conduct in all our operations. As a provider of human resource services to SMEs and SMIs in Malaysia, we value honesty and accountability, and we encourage anyone with genuine concerns about potential wrongdoing to come forward without fear of reprisal.

This Whistleblowing Policy provides a safe and confidential channel for employees, contractors, clients, suppliers, business partners, and members of the public to report any suspected Improper Conduct. We align our approach with the principles of the Whistleblower Protection Act 2010 and relevant Malaysian laws.

What Constitutes Improper Conduct?

Improper Conduct includes, but is not limited to:

• Fraud, corruption, bribery, or theft
• Violation of laws, regulations, or company policies
• Financial mismanagement or irregularities
• Abuse of authority or position
• Actions that endanger health, safety, or the environment
• Any other unethical, dishonest, or illegal behavior that could harm Zavarco, its people, clients, or stakeholders

How to Report

If you have reasonable grounds to believe that Improper Conduct has occurred, is occurring, or is likely to occur, please report it promptly through the following channels:

• Email: [compliance [at] zavarco.com] (or a designated confidential email)
• Direct contact: Senior Management or the designated Compliance Officer
• Anonymous reports are accepted, though providing contact details (if comfortable) helps us investigate more effectively

Reports should include as much detail as possible, such as what happened, when and where, who was involved, and any supporting evidence.

Protection for Whistleblowers

We are committed to protecting individuals who report in good faith:

• No retaliation, harassment, or detrimental action (such as dismissal, demotion, or unfair treatment) will be taken against you for making a genuine disclosure.
• Your identity and the details of your report will be kept confidential to the extent possible, shared only with those directly involved in the investigation.
• Protection is provided in line with applicable laws, including the Whistleblower Protection Act 2010.

Note: Protection may not apply if the report is found to be malicious, frivolous, or made in bad faith.

Investigation Process

All reports will be treated seriously and handled promptly, fairly, and impartially:

• A preliminary assessment will determine the appropriate next steps.
• Qualified individuals or an independent party may investigate as needed.
• You may receive updates on the progress (subject to confidentiality) and, where appropriate, the outcome.

Our Commitment

Zavarco PLC fosters an open culture where raising concerns is seen as a positive contribution to our integrity and success. We do not tolerate any form of retaliation against those who speak up responsibly.

For questions about this policy or to make a report, please contact our Compliance Officer or senior leadership.

This policy is reviewed periodically to ensure it remains effective and compliant with relevant requirements.