COMPLIANCE

These policies shall apply to ORIX Leasing Malaysia Berhad [Business Registration No.: 197301002250 (15741-D)] and its related companies as defined under Section 7 of the Companies Act 2016 (collectively referred to as "OLM Group").

OLM Group has established group-wide regulations on compliance, and has prescribed, while also endeavouring to promote, rules and codes of conduct that will keep directors, officers and employees of OLM Group adhering to the law, internal regulations, social norms, etc. Our policy expresses the standards of business integrity that we require from our officers and employees in promoting a culture of compliance and emphasising high standards of ethical behaviour at all levels within the organisation to comply fully with all applicable Laws and Corporate Policies. The “OLM Group Code of Conduct” sets out the basic principles of conduct to be observed by all the officers and employees of OLM Group.

OLM Group maintains the highest ethical standards, adheres to all applicable laws, and endeavours to make sure that its officers, employees, and representatives do not perform any acts over the course of business that may appear inappropriate. This policy prohibits improper payments, gifts, gratifications, or inducements of any kind to and received from any person, including officials in the private or public sector, customers, agents, and intermediaries.

OLM Group will not participate in any transactions related to revenue arising from any unlawful activities, transactions that finance terrorist activities or that are prohibited from being traded with by foreign governments. OLM Group's policy on Anti-Money Laundering (AML) has been prescribed to comply with the Standard Guidelines on AML / Counter Financing of Terrorism issued by the Financial Intelligence & Enforcement Department of Bank Negara Malaysia and in compliance with the AML, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001.

This policy has prescribed the basic matters required for the management of insider information, etc. obtained by officers and employees of OLM Group over the course of their business, for regulating the trading of shares, etc. as well as the matters for officers and employees to adhere to, and endeavours as a matter of course to prevent insider trading and other unfair purchases and sale transactions.

The policy has prescribed OLM Group’s standard for avoiding conflicts of interest, and in the event of an officer or employee of OLM Group faces a situation where there is a business-related conflict of interest, or suspicion of such a conflict of interest, OLM Group endeavours to ensure that this is handled appropriately.

The policy has prescribed the guidelines and minimum standards for giving and receiving of gifts and hospitality by employees to / from business partners, public officials and etc. OLM Group’s employees are prohibited from receiving or giving gifts and hospitality as a means to obtain unfair gain, and endeavours to conduct transactions with customers, third parties, public officials, etc. in a fair and transparent manner.

WHISTLEBLOWER POLICY

OLM Group believes in the conduct of its business and affairs in a fair and transparent manner by adopting the highest standards of professionalism, integrity, and ethical behaviour. Any actual or potential exceptions to the same would be a matter of serious concern of OLM Group. It is in the best interests of the organisation that such exceptions are reported for taking timely remedial measures, immediate as well as long-term. While OLM Group employees have always been expected to practise ethical behaviour and be vigilant to any exceptions coming to their knowledge, the same responsibility is now being codified by way of a "Whistleblower Policy”.

The said policy has been developed to ensure that compliance concerns are investigated confidentially, promptly, and to give protection to persons who disclose compliance concerns so that they report the same without any fear of victimisation or adverse action.

The Whistleblower Policy prohibits the performance of unfair treatment on whistleblowers and persons who have cooperated with investigations, and in addition, obligates all officers and employees to, in principle, immediately report to their superior if they learn of a legal violation, rule violation, or act that is contrary to public order and morals, etc. or have a suspicion that this may be the case, and if reporting to a superior is difficult, to consider other reporting channels available such as the email address stated in the final paragraph of this notice.

After receiving a report, based on the management of the designated information recipient, a review committee and investigation committee, investigation and corrective action, etc. will be formed with careful management of the reported information, and forthwith report the findings to the OLM Group Audit Committee. Appropriate action shall be taken against the offending employee.

Whistleblowing channels have been established both internally and externally. Any compliance concern can be emailed to integrity@orix.com.my.