Objective

AirAsia X Berhad's Whistleblowing Policy is to enable genuine and legitimate concerns to be raised by employees, directors and others. The policy provides an opportunity for those concerns to be investigated and for appropriate action to be taken to ensure that the matter is resolved effectively and within the Company wherever possible.

Scope

AirAsia X Berhad requires all employees and directors to comply with applicable laws, rules, regulations and Company policies. To provide procedures for reporting potential and actual violations relating to any law, rule, regulation or Company policy, the Company has established this Whistleblowing Policy, which:

1. Governs the process through which employees, directors and others may report:

    Please rotate your screen or scroll left and right if you cannot see the table.

   Concern should be reported
   Commission of fraud and/or corruption	Non-compliance with Company's policies and procedures and/or code of conduct
   Negligence	Unauthorised use of Company's money, properties and/or facilities
   Disclosure of Company's Information without proper authorisation	Exposure of Company's property, facilities and/or staff to the risks of safety and security
   Commission of acts which intimidate, harass and/or victimise any members of the Board of Directors, Management or employees of the Company	Abuse of position
   Involvement in conflict of interest and/or business opportunities positions	Commission of unlawful acts
   Failure to meet professional standards	Concealment of any of the above

    

   Concern should not be reported

   False and malicious concerns

   Defaming concerns

   Concerns without any basis or insufficient evidence





2. Establishes a mechanism for responding to any reports from employees, directors and others regarding such potential violations or concerns;

3. Prohibits retaliation against employees raising such potential violations or concerns; and

4. Establishes procedures for the retention of records of reports.

 

Responsibilities

Head, Internal Audit

• To compile all reports received and submit to the Chairman of the Board, Audit Committee (BAC).

• To report to Management the results of the investigation for further action.

Procedure

• AirAsia X encourages employees, directors and others to raise their concerns through this whistleblowing procedure. Allegations raised must be made in writing and it must be made clear that the complainant considers the matter to be one of whistleblowing.

• When reporting a violation or concern - the time, location and nature of the matter, the names of people involved and other details should be provided so it can be investigated. Allegations about issues falling within the scope of paragraph 1.1 above, may be reported by completing the form in Appendix 1 and then email to the Head of Internal Audit at aax_whistleblower@airasia.com

• If the subject of allegations pertains to the Head of Internal Audit, this may be reported by completing the form in Appendix 1 and then email to the Chairman of the BAC at aax_chairman_bac@airasia.com

Handling Reports

• The Company will treat all reports with the utmost seriousness and will thoroughly review each such report and the allegations set forth in the report. The Company expects every employee, director and others to make every reasonable effort to assist persons involved in reviewing and investigating any report, including making himself or herself available for interviewing, responding to requests for documentation or other information, etc. Where appropriate, the Company will notify the individual who submitted a report of the outcome of his or her submission.

• The Head of Internal Audit will immediately notify the BAC in writing of all reports received. The Head of Internal Audit will also send to the BAC an unedited, exact copy of each such report. The Chairman of the BAC will undertake a preliminary investigation of the allegation.

• As soon as practicable after receipt of a report, the Chairman of the BAC will prepare and deliver to the BAC a written report:

  1. summarising the allegations raised and the preliminary investigation of these allegations; and

  2. (ii) providing a recommendation as to what additional action, if any, should be taken. As soon as practicable after receiving the Chairman of the BAC's written report, the BAC will convene a special meeting to review and consider the report. Upon review and consideration of the report, the BAC will consider what further action, if any, will be taken.

• The BAC shall have the authority to engage outside auditors, counsel, or other experts to assist in the investigation and analysis of any report.

• It is the responsibility of the BAC to report the results of their investigations to Company management any non-compliance with laws, rules, regulations or Company policy.

• The BAC will coordinate with the Head of Internal Audit to ensure that Company management takes necessary corrective action including, where appropriate, reporting any violation to the relevant federal, state or other law enforcement, governmental or regulatory authorities.

• At each regularly scheduled quarterly meeting of the BAC, the Head of Internal Audit will present a summary to the BAC stating the nature of each report submitted during the quarter immediately preceding the Board meeting, what further actions, if any, were taken with respect to each report, and the status of any further action taken.

• Reports filed under this policy will be controlled and documented by the Head of Internal Audit, who shall maintain all related documentations for seven years. All related documentation shall be maintained in secured files to which only the Head of Internal Audit and the BAC members shall have full access.

Confidentiality And Retaliation

• Retaliation against any individual who submits a report, provides information or otherwise participates in an investigation is strictly prohibited by Company policy and will not be tolerated.

• Neither the Company, its Board of Directors, nor any of the Company's employees, officers or directors will retaliate or tolerate any retaliation against any individual who, in good faith and in accordance with this Whistleblowing Policy, makes a report or provides assistance to the Head of Internal Audit, the BAC, or any other person or group, including any governmental, regulatory or law enforcement body, investigating a report,

• Furthermore, the Head of Internal Audit and the BAC shall not, unless compelled by judicial or other legal process, reveal the identity of the individual who submits a report and who requests that his or her identity as the person who submitted the report remain confidential.

Performance Measures & Non-Conformance Criteria

Report issuance time - Within 14 working days after a complaint has been received

Records