1. Purpose

Cairns Multitrade is committed to promoting a culture of honesty, accountability, and ethical behavior. This policy provides a structured process for reporting unethical, illegal, or improper conduct within the company. It ensures that all concerns are addressed in a confidential and professional manner while protecting the rights of individuals who report in good faith.

2. Scope

This policy applies to all Cairns Multitrade employees, contractors, suppliers, and other stakeholders. It covers concerns related to:

• Fraud or financial mismanagement
• Corruption or bribery
• Harassment or bullying
• Health and safety violations
• Environmental hazards
• Violations of company policies or codes of conduct
• Any legal or regulatory breaches

3. Reporting Procedure

Cairns Multitrade encourages anyone who has concerns regarding unethical or illegal practices to report their observations through the following channels:

• Direct Reporting: Employees can report concerns directly to their line manager or the Human Resources department.
• Compliance Reporting: Reports can also be submitted to the Ethics and Compliance team at shahiran@cairns-moneychanger.com.my.
• Anonymous Reporting: Those wishing to remain anonymous can use our confidential reporting system via shahiran@cairns-moneychanger.com.my.

4. Confidentiality and Protection

All reports will be treated with the utmost confidentiality. Cairns Multitrade is committed to ensuring that individuals who report concerns in good faith are protected from retaliation, discrimination, or harassment. Any form of retaliation will not be tolerated and may result in disciplinary action.

5. Investigation Process

Once a report is received, the Compliance Officer or a designated investigator will review the case. If necessary, a formal investigation will be initiated. All investigations will be conducted impartially and in a timely manner. Every effort will be made to maintain confidentiality and protect the rights of all parties involved.

• Timeline: Initial assessments will be completed within 10 business days, and more complex investigations will be conducted within 30 days.
• Communication: The reporter will be informed about the progress and outcome of the investigation, where possible.

6. Outcomes

If the investigation confirms misconduct or violation of ethical standards, Cairns Multitrade will take appropriate corrective action. This may include disciplinary action up to and including termination of employment, legal action, or revising company policies to prevent future violations.

7. False Reporting

Cairns Multitrade encourages honest and responsible reporting. However, any deliberate false reporting intended to harm others will be treated as a serious offense and may result in disciplinary measures.

8. Review of Policy

This Ethics and Compliance Reporting Policy will be reviewed annually to ensure it remains relevant and aligned with legal requirements and best practices in corporate governance.