SEGMENT KEY INTERNAL CONTROL ELEMENTS Code of Conduct The Code of Conduct contains policies and guidelines relating to the standards and ethics that all employees are expected to adhere to in the course of their work. It is designed to maintain discipline and order in the workplace among employees of all levels. It also sets out the circumstances in which such employees would be deemed to have breached the Code of Conduct and the actions that can be taken against them if they do so. All employees are strictly required to adhere to DNeX Group’s Code of Conduct in order to ensure a high level of discipline and integrity in carrying out duties. Anti-Bribery and Anti-Corruption Framework and Policy (“ABAC”) Following the enforcement of Section 17A of the Malaysian Anti-Corruption Commission Act 2009 and the Malaysian Anti-Corruption Commission (Amendment) Act 2018 that took effect on 1 June 2020, the Board had on 29 May 2020 approved the ABAC to ensure that adequate procedures are in place to prevent persons associated to DNeX Group from undertaking such conduct of corruption and bribery. Any type of corruption and bribery of any nature, directly or indirectly, in order to influence any type of decision that may result in an undue benefit or advantage to DNeX Group will not be tolerated. The key features of the ABAC are measures established to control such misconduct at strategic, tactical and operational levels. It outlines the actions that need to be taken to prevent, detect and report potential threats and any corruption risks. It serves to reinforce DNeX Group’s commitment to good governance and transparency, and shall further guide how employees and related parties shall continue to conduct business with honesty, fairness and high ethical standards, and not allowing certain types of behaviour contrary to commercial integrity which can compromise DNeX Group’s reputation. Whistleblowing Framework and Policy The Whistleblowing Framework and Policy aims to provide a structured mechanism for DNeX Group’s employees and any reporting parties to raise or report any suspected or known misconduct. The Whistleblowing Framework and Policy is administered by The Risk, Governance & Sustainability Committee and disclosure via a Whistleblower Report Form can be made to the established channel. Consistent with the need to conduct adequate investigation, the whistleblower’s identity and report will be treated by DNeX Group as confidential to the highest extent possible. The Group Human Resource, Risk and Sustainability and Management Information System departments have carried out several internal awareness campaigns in relation to the Code of Conduct, ABAC, Whistleblowing as well as Information Technology Security Awareness Training to inculcate a stronger focus on DNeX Group’s core values and the compliance culture that need to be observed by all employees. Investment Framework and Policy The establishment of the Investment Framework and Policy on 8 October 2021 with subsequent revision on 27 November 2025 is to serves as a clear and consistent reference for the Group’s investment and divestment decisions. Further, the Policy is also intended to define the roles and responsibilities of relevant parties, outlines the required workflows, checklists, and documentation for the submission and approval of investment/divestment proposals. STATEMENT ON RISK MANAGEMENT AND INTERNAL CONTROL DNeX INTEGRATED REPORT 2025 116 ABOUT THIS REPORT LEADERSHIP VALUE CREATION @DNeX LEADERSHIP INSIGHTS OVERVIEW OF DAGANG NeXCHANGE BERHAD
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