1. Introduction

At PulseLink Digital Sdn Bhd (“PulseLink”), we believe in doing the right thing. We value integrity, honesty, and transparency in everything we do. We also want to create a safe and respectful workplace where employees and other stakeholders can raise concerns about wrongdoing without fear.

This policy explains how anyone—whether you are an employee, vendor, contractor, or even a customer—can report concerns about unethical behavior, misconduct, or illegal activities in a confidential and protected way.

2. Legal Framework

This policy is guided by the following Malaysian laws:

• Whistleblower Protection Act 2010 – Protects whistleblowers who report genuine concerns from retaliation and keeps their identity confidential.
• Malaysian Anti-Corruption Commission (MACC) Act 2009 – Addresses bribery, corruption, and abuse of power in both public and private sectors.
• Companies Act 2016 – Emphasizes proper governance, transparency, and responsibility among directors, officers, and companies.

These laws provide the legal backing for this policy and support PulseLink’s goal of building a strong ethical culture.

3. Purpose of the Policy

The main goals of this policy are to:

• Encourage people to report suspected wrongdoing or unethical behavior.
• Provide a safe and secure way to report these issues.
• Ensure that all reports are handled fairly and responsibly.
• Protect whistleblowers from retaliation or harm.
• Uphold our legal and ethical responsibilities as a tech company in Malaysia.

4. Who Can Report (Whistleblower Eligibility)

This policy is open to:

• Employees (full-time, part-time, interns)
• Vendors and suppliers
• Contractors and consultants
• Customers and business partners
• Any other person connected to PulseLink

You don’t need to have proof. If you have a genuine concern and report it in good faith, your report will be taken seriously.

5. What Can Be Reported

You can report any act that is:

• Illegal (e.g., theft, fraud, corruption, data breaches)
• Unethical (e.g., conflict of interest, insider trading)
• Unsafe (e.g., violations of health or safety laws)
• Against company policies or values
• Abuse of power, harassment, or discrimination

If you’re unsure whether something is reportable, it’s okay—still come forward and let the team assess it.

6. How to Report a Concern

You can report concerns in any of these ways:

• Email: whistleblow@pulselinkdigital.com
• Mail or Letter (marked “Private & Confidential”):

Attn: Whistleblowing Committee
PulseLink Digital Sdn Bhd
Unit 3.07, Level 3, KL Gateway Mall
No. 2, Jalan Kerinchi
59200 Kuala Lumpur, Malaysia

Please provide as much detail as possible, such as:

• What happened
• When and where it happened
• Who was involved
• Any documents or evidence (if available)

7. What Happens After a Report is Made

1. Acknowledgement – We will confirm we received your report within 5 working days.
2. Initial Review – The Whistleblowing Committee will review your report to decide what to do next.
3. Investigation – If needed, a confidential investigation will begin. We may ask you for more details.
4. Outcome – Once the investigation is complete (normally within 30 working days), appropriate action will be taken if wrongdoing is found.
5. Confidential Record Keeping – A secure record of the case and results will be kept.

All investigations are conducted fairly, thoroughly, and with confidentiality.

8. Whistleblower Protection

We take protection seriously. If you make a report in good faith:

• Your identity will be kept confidential, unless we are required by law to reveal it.
• You will be protected from retaliation, such as threats, demotion, suspension, or harassment.
• You will not face legal or disciplinary action for raising a concern, even if it turns out to be untrue—as long as you were honest and acted in good faith.

However, if someone makes a false report on purpose, they may face disciplinary or legal action.

9. Confidentiality and Anonymity

• You may choose to remain anonymous, though providing your identity can help us follow up more effectively.
• We will take every possible step to keep your report and identity private.
• All records will be stored securely and access will be restricted to only those managing the investigation.

10. Roles and Responsibilities

Board of Directors

• Oversees and approves the Whistleblowing Policy.
• Receives periodic updates on reported cases and resolutions.

Whistleblowing Committee

• Receives and investigates reports.
• Ensures confidentiality and fair handling of each case.
• Recommends actions to management or the Board.

All Employees and Stakeholders

• Are responsible for reporting genuine concerns.
• Must cooperate in any investigations if asked.
• Must not engage in retaliation or discourage others from reporting.

11. Recordkeeping and Monitoring

All whistleblowing reports and outcomes will be securely documented and kept for at least 7 years. A summary (without revealing identities) will be shared with the Board of Directors to monitor trends and improvements.

12. Review of Policy

This policy will be reviewed once a year, or sooner if laws or business practices change. Updates must be approved by the Board of Directors.

13. Questions or Advice

If you’re unsure whether your concern falls under this policy, or you need advice on how to report, you may contact:

Email: ask@thepulselink.io
Phone: 011-55812200 / 011-55842200