Governance

Whistleblowing

If you see bribery, corruption, fraud or serious misconduct connected to our work, tell us. This page explains how to report it, what we will do, and the protection you have under Malaysian law.

Report a concern Report to the authorities

Our commitment

Topina Builder Sdn Bhd does not tolerate bribery, corruption, fraud or abuse of position — by our directors, our employees, or anyone acting for us or on our behalf. That includes subcontractors, suppliers, consultants and agents.

We work for government agencies, property developers and main contractors, and we compete for public tenders. Section 17A of the Malaysian Anti-Corruption Commission Act 2009 makes a company criminally liable when someone associated with it gives or offers a bribe for the company’s benefit. A reliable, confidential reporting channel is one of the adequate procedures a company is expected to have in place. This policy is that channel.

Raising a genuine concern will never cost you your job, your contract, or your place on our tender list. That commitment is given by the Board of Directors and applies to everyone who reports honestly, even if it later turns out they were mistaken.

What you can report

Any improper conduct connected to our business or our sites. You do not need proof, and you do not need to be certain — a reasonable, honestly held suspicion is enough.

Bribes, kickbacks, secret commissions or facilitation payments, whether given, received, offered or requested

Corruption in tendering or procurement — bid-rigging, collusion, leaking tender information, or steering an award

Fraud, forged or falsified records, inflated progress claims, or invoices for work not carried out

Undeclared conflicts of interest, including undisclosed family or financial ties to a supplier or client

Theft or misuse of company money, plant, fuel or site materials

Deliberate breaches of safety, environmental or statutory requirements that put people at risk

Any attempt to conceal the above, or to retaliate against someone who speaks up

Who can report

Anyone. This channel is open to our own people and to everyone outside the company who deals with us or is affected by our work.

Directors, managers, site staff and workers, at any level and on any site

Subcontractors, suppliers, consultants and their employees

Clients, main contractors, joint-venture partners and government officers

Neighbours, residents and members of the public near our sites

How to report

Use any of the channels below. Reports go to a Director and are handled in confidence.

By email

Mark your message for the attention of the Director and use this exact subject line so it is not opened as a general enquiry:

info@topinabuilder.com.my

PRIVATE & CONFIDENTIAL — WHISTLEBLOWING

By post

Seal the envelope and mark it Private & Confidential. Post is the surest way to report anonymously.

The Director — Private & Confidential
Topina Builder Sdn Bhd
B1-19-G, Space U8, No. 6, Persiaran Pasak Bumi,
Taman Bukit Jelutong, Seksyen U8,
40150 Shah Alam, Selangor

You may also ask any Director for a private meeting, and you may bring someone with you.

Reporting anonymously

You do not have to give your name. We will still assess an anonymous report and act on it where we can. Be aware that anonymity has a practical cost: we cannot come back to you for detail, we cannot keep you updated, and we cannot extend the protections in section 06 to a person we cannot identify. Where you are willing to be identified, that usually leads to a better outcome.

What to include

Tell us as much as you reasonably can. Even a partial account is worth sending.

What happened, and what makes you think it was improper

Who was involved, and their role or company

When and where it happened, and which project or site

Whether it is still going on

Any documents, photographs or messages that support it — but never put yourself at risk to obtain evidence

Whether you have reported it to anyone else, inside or outside the company

What happens next

We acknowledge your report within five working days, where you have given us a way to reply

It is assessed by a Director with no involvement in the matter and no interest in its outcome

Where a review is warranted we carry one out, and we appoint an independent external adviser if the matter concerns a Director or is otherwise too close to home

Anyone the report concerns is dealt with fairly, and no conclusion is drawn until the facts are established

Where there are reasonable grounds to believe an offence has been committed, we report it to the Malaysian Anti-Corruption Commission or the police — a report to us is never a substitute for that

We tell you the outcome so far as we are legally able to, and we keep a confidential record of every report and what was done about it

Confidentiality and no reprisals

We treat your identity as confidential. We disclose it only where the law requires it, or where it is genuinely unavoidable to deal with the matter — and where we can, we will tell you before that happens and discuss it with you.

Retaliation against anyone who raises a genuine concern, or who assists a review, is prohibited. That covers dismissal, demotion, transfer, loss of hours, withheld payment, exclusion from future tenders, termination of a subcontract, harassment and threats. Retaliation is treated as misconduct in its own right and is grounds for disciplinary action or termination of a contract, whether or not the original concern turns out to be well founded.

Reporting honestly does not protect you from the consequences of your own wrongdoing, but coming forward voluntarily will be taken into account in your favour.

A report you know to be false, or one made to harass someone or to gain an advantage, is not protected by this policy and may itself be treated as misconduct.

Your protection under Malaysian law

Reporting to us is not the same as making a protected disclosure under the Whistleblower Protection Act 2010. Read this section before you decide where to report.

The statutory protections under that Act — confidentiality of your identity and your information, immunity from civil, criminal and disciplinary action for making the disclosure, and protection against detrimental action — attach to a disclosure of improper conduct made to an enforcement agency, such as the Malaysian Anti-Corruption Commission. A disclosure made only to a private company does not attract them.

The commitments in sections 05 and 06 above are given by Topina Builder as a matter of company policy. We hold ourselves to them, and we intend them to be relied on — but they are our own undertakings, not the protections the Act confers.

The Act also allows protection to be revoked in defined circumstances, including where the person who disclosed took part in the improper conduct themselves, or made the disclosure knowing it to be materially false. Parliament passed amendments to the Act in 2025 which narrow some of those grounds. If you intend to rely on the Act, check the position in force at the time and consider taking independent legal advice.

Nothing in this policy prevents you from reporting to an enforcement agency, a regulator or the police. You do not need our permission, you do not have to come to us first, and you do not have to tell us that you have done so.

Reporting to the authorities

For corruption and bribery, report to the Malaysian Anti-Corruption Commission (SPRM). Reports to the Commission are treated as confidential.

Malaysian Anti-Corruption Commission (SPRM)

Hotline: 1-800-88-6000 (toll free)
Online: portaladuan.sprm.gov.my
Email: info@sprm.gov.my
In person: Any MACC state or district office
By post: Suruhanjaya Pencegahan Rasuah Malaysia,
No. 2, Lebuh Wawasan, Presint 7,
62250 Putrajaya

For conduct that may be a criminal offence more generally, report to the Royal Malaysia Police at any district police station. Where there is an immediate risk to life or safety, call 999 first.

About this policy

Applies to: All directors and employees of Topina Builder Sdn Bhd, and everyone who performs work or services for us or on our behalf
Owned by: The Board of Directors, which is accountable for how reports are handled
Effective: 27 August 2026
Review: Annually, or sooner if the law changes

This page is a statement of company policy and general information. It is not legal advice, and it does not add to or limit any right you have under Malaysian law.