Whistleblower Policy

Last updated: May 2023


Halogen Capital Sdn. Bhd. (Halogen) is committed to maintaining a culture of the highest ethics and integrity in compliance with all applicable laws, regulations, and internal policies.

As part of this commitment, Halogen has in place an avenue for disclosure of any improper conduct. One way for Halogen to detect and deal with improper conduct is through information provided by whistleblowers. Generally, a whistleblower is an insider of an organisation (e.g. employee, consultant or vendor) who reports improper conduct that has occurred within that same organisation.

In an effort to encourage whistleblowers to come forward with information on any alleged improper conduct, the Whistleblower Protection Act 2010 provides safe avenues for them to make disclosures of such alleged improper conduct (whistleblowing) to the relevant authorities in good faith, by protecting their identities, providing them with immunity from civil and criminal proceedings and protecting them from detrimental action. 

Who is a Whistleblower?

Under the Policy, any of the following persons can be a Whistleblower: 

  1. Any employee, agent, or office-bearer in Halogen;
  2. External parties, such as Halogen’s customers, service providers, vendors, consultants, or shareholders.

Confidentiality and Protection of Whistleblower

The identity of a whistleblower who disclosed good faith will be kept confidential and will only be disclosed on a strictly need-to-know basis. Employees who whistleblow in good faith will also be protected by Halogen from any repercussions. 

Disclosures of an Improper Conduct can be made by submitting the Whistleblowing Form below via any of the following channels: 

Download Halogen Capital - Whistleblowing Form.pdfEmail: whistleblowing@halogen.my 
Letter: Halogen Capital - Group Compliance Department, 3.02A & 3.02B, Level 3, Menara BRDB, 285, Jalan Maarof, Bangsar, 59000 Kuala Lumpur, Malaysia 

To facilitate the investigation, details, and information on the concern made by the Whistleblower should include name(s) of the person(s) involved, date and location of the event, and provide supporting documents/proof. 

Any reports of Improper Conduct committed by market participants and/or any breach of the securities laws by any market participant should be channelled to the Securities Commission which is an “enforcement agency” under the Whistleblower Protection Act 2010 (“Act”). 

Requirement of Good Faith 
Since an allegation of Improper Conduct may result in serious personal repercussions for the person who has allegedly committed an Improper Conduct, any person who intends to lodge any report of Improper Conduct shall ensure that the report of Improper Conduct is made in good faith. 

Any person making an allegation of Improper Conduct must have reasonable and probable grounds before reporting such Improper Conduct and must undertake such reporting in good faith, for the best interest of the Company and not for personal gain or motivation.

Exclusion from Protection

Potential whistleblowers are also reminded that there may be instances wherein their protection would be revoked or excluded. The whistleblower protection does not extend to the following disclosures and will be revoked by Halogen pursuant to section 11 of the Whistleblower Protection Act 2010: 

  • where the whistleblower has participated in the improper conduct so disclosed; 
  • where the whistleblower commits an offence under the Whistleblower Protection Act 2010; 
  • where the disclosures of improper conduct which contain information specifically prohibited from being disclosed under any written law such as the Official Secrets Act 1972;
  • where the disclosures of improper conduct which are:
    - frivolous or vexatious;
    - principally questioning the merits of government policy, including policy of a public body; 
    - known to the whistleblower to be false or untrue; or 
    - made solely or substantially to avoid dismissal or other disciplinary action.

Any person who makes a disclosure of improper conduct to the Company, knowing or believing that any material statements in the disclosure is false or untrue commits a criminal offence under the Whistleblower Protection Act 2010.