Policy on Disclosure of Sensitive/Confidential Matters to Management

Introduction

CPCPA believes that the key to long-term sustainability and success largely depends on having a good name and solid reputation in the marketplace.
To achieve this, the Company is committed to the highest standards of ethical values, integrity, honesty, accountability, and transparency in the conduct of its business.
Under applicable corporate governance principles, CPCPA employees should be given the opportunity to communicate, with protection from reprisal, legitimate concerns about illegal, unethical, or questionable practices—otherwise known as “whistle blowing.”

Scope of the Policy

This policy covers the reporting of any incident, situation, circumstance, or problem involving fraud and/or violation of company policies for further investigation, which may result in or has resulted in monetary loss and/or negative impact on the Company’s image. This includes legitimate concerns about illegal, unethical, or questionable Related Party Transactions (RPTs).

Obligation to Report

Any person who has knowledge of, or has observed a reportable concern, is required to file a report of such act or event to the designated/appropriate authority.

Reporting Process

Reports may be submitted through SMS, letter, email, or phone call directly to the Office of the President or the appropriate Head of Unit.
If the concern involves the President or Executive Officers, reports should be addressed to the Board of Directors through the Chairperson’s Office.
For RPT-related concerns, reports should be addressed to the Chairperson of the Related Party Transactions Committee.

Handling of Reported Cases

To facilitate the investigation process and urgent administrative action if necessary, the report must contain
the nature of the concern, relevant details of transactions (type, amount/s and date/s), person/s involved,
and supporting documents, if any, including an explanation on why it is a reportable concern. A signed
confidential report is encouraged as opposed to an anonymous report because of the need to clarify the
contents of the disclosure or request for additional information that may be required before or during the
investigation. A report form will be made available through CPCPA’s internal system for submitting a report.

1. The reporting person may call via CPCPA official mobile numbers 0993 433 9738 or 0966 814 4244 and ask to be connected to the Office of the President or the Head of the Unit concerned. In the case of shareholders, they may contact the Corporate Planning or Compliance Officer via phone at the same numbers or email at ceocharlescatipay.cpcpa@gmail.com. In the case of customers, they may reach out through CPCPA’s official customer service channels or the same contact details listed above.
2. If the concern involves the President or Executive Officers, the reporting person may call 0993 433 9738 or 0966 814 4244 and request to be transferred to the Office of the Chairperson of the Board.
3. For Related Party Transaction (RPT)-related concerns, the reporting person may call 0993 433 9738 or 0966 814 4244 and ask to be connected to the Chairperson of the RPT Committee, through the Office of the Corporate Secretary.

Confidentiality

All reports will be treated with the utmost confidentiality. CPCPA will protect the identity of the whistle blower from disclosure unless legally required.
The same level of confidentiality is expected from the whistle blower.

Retaliation and Harassment

CPCPA will not tolerate retaliation, harassment, or informal pressure against whistle blowers acting in good faith.
If the report is made in bad faith or based on false information, the whistle blower may face disciplinary action.

Policy Oversight and Ownership

The Compliance Unit is responsible for policy implementation and enforcement. The Head of the Cases Review Committee Secretariat will submit monthly reports to the
Chief Compliance Officer, the Cases Review Committee, and the Audit Committee. Periodic updates may be shared with the Board of Directors.

Approval and Disclosure

This policy is approved by the Board of Directors and will be disseminated to all directors, officers, and staff.
It will be available on the Company’s website and intranet and will form part of CPCPA’s HR and compliance manuals.