Introduction
Myanmar Distillery Company Limited (“MDC”) encourages all employees to report any well-founded suspicious wrongdoings as soon as practically possible. Suspected wrongdoings within MDC will be taken seriously and employees will not be victimized or subject to any detriment if he/she raises legitimate concerns in good faith.

The purpose of this policy is to encourage the reporting in good faith of suspected wrongdoing by establishing clearly defined processes through which such reports nay be made with confidence that persons making such reports will be treated fairly and, to the extent possible. protected from reprisal.

It should be noted however that persons who tile reports or provide evidence which they know to be false. or without a reasonable belief in the truth and accuracy. of such information, will not be protected by this policy and may be subject to administrative and/or disciplinary action including termination of employment or other contract, as the case may be.

Scope of the Policy

The Whistleblowing Policy (“Policy”) applies to all MDC directors (“Directors”), Executive officers and employees (“Employees”).

1. Purpose

1.1 The Policy provides a procedure to ensure that concerns about suspected wrongdoings within MDC (`Whistleblowing”) are raised and handled timely and appropriately. It applies to Directors and Employees identified in MDC’s regulations which currently consist of Permanent Employees. Contracted Employees and daily wage employees.

1.2 Employees are encouraged to report genuine concerns which they may have about suspected wrongdoings in accordance with the Policy. in the knowledge that their concerns will be taken seriously and investigated as deemed appropriate. MDC will support them. provided that that they raise genuine concerns in good faith, even if they turn out to be mistaken. Reasonable measures shall be taken to protect Directors and Employees from detriment, retribution or harassment from doing so.

2. Definition of Whistleblowing

Whistleblowing is the disclosure of information relating to wrongdoings or dangers at work. This includes criminal activities and other unlawful conduct, failure to comply with regulatory requirements. financial irregularities and actions that are dangerous to the health and safety of people or to the environment. For example. insider dealing, bribery, forgery and misuse of confidential records and proprietary information would constitute wrongdoing.

3. When to apply the Policy

Directors and Employees shall mixed in accordance with the Policy if they have a genuine concern about past. current or future wrongdoings or dangers. It may not always be clear whether the conduct which concerns Employees amounts to wrongdoing and Employees will need to form their own judgment. MDC encourages Employees to report their concerns when in doubt.

4. How to report a concern

4.1 If Directors have concerns. they should consider to consult the Chairman of the Audit Committee (“Audit Committee Chairman”).

4.2 If Employees have concerns. they should consider the process set out below and report them through the recommended channels) in writing with their name and COMM details.

4.3 Employees are encouraged to report their concerns to their supervisor. who is in turn is responsible for promptly informing Head Internal Audit. However, if the supervisor is of the view that the Head Internal Audit is. or may be. in a conflict of interest position. he/she may inform the Audit Committee Chairman. instead of the I lead Internal Audit. about his/her concerns. In any event. the supervisor must not stan any investigation

4.4 If Employees prefer not to disclose the matter to their supervisor, they may report to the Head Internal Audit or Audit Committee Chairman.

4.5 The Head Internal Audit shall promptly refer the Whistleblowing Reports to the Audit Committee Chairman.

4.6 The Audit Committee Chairman will review the information disclosed, interview the Whistle-Blower(s) when required and. either exercising his own discretion or in consultation with the other Audit Committee members, determine whether the circumstances warrant an investigation and if so. the appropriate investigative process to be employed and corrective actions (irony) to take.

4.7 Any Directors and Employees mho Inn e any personal interest in the matter are obligated to declare it upon raising the concerns.

4.8 The Head Internal Audit will retain all documents related to Whistleblowing Reports in a sale. secure and proper manner.

5. Confidentiality

MDC encourages Employees to raise any genuine concerns openly under the Policy. However. MDC will not respond to disclosures made anonymously, since it will make proper investigation difficult or even impossible and may lead to groundless accusations. If Employees would like to raise concerns confidentially, MDC will take reasonable steps to keep Employees’ identity secret. Disclosure of Employees’ identity may, however, become unavoidable in the case of an investigation by government officials or court proceedings.

6. How MDC will handle the matter

6.1 Once Director(s) have reported their concern under the clause 4.1. the Audit Committee Chairman will consider and lake necessary action.

6.2 Once Employee(s) have reported their concern. the matter will be assessed to determine the proper action to be taken. which might include internal investigation or a referral for external investigation. Employees will he informed about who is responsible for handling the matter. how the person can he contacted and whether any further assistance may be needed from Employees. Employees may, for example. be required to attend additional meetings in order to provide further information.

6.3 MDC may. where confidentiality allows. provide Employees feedback, including the progress of the investigation and likely timescale. but MDC is not obliged to do so. Nonetheless. confidentiality may hinder MDC from providing Employees with details of the investigation or disciplinary punishment which may result from the whistleblowing action. Employees must treat any information given to them about the investigation as entirely confidential.

6.4 If it is considered more appropriate to deal with concerns of Employees as a grievance matter as stated in the “Employee Handbook of MDC”. Employees will be informed accordingly. In this case. Employees’ concerns will be further submitted through the responsible departments or divisions or offices.

7. Warning on misuse of the Policy and protection to the whistle-blower

7.1 Any complaint which is later found false. or made in bad faith. with malicious intent. in a careless manner. or for personal benefit is considered a serious violation. Such action is considered gross misconduct and will lead to disciplinary action described in the “Employee handbook of MDC.

7.2 MDC will not tolerate harassment or victimization of Employees raising a genuine concern under the Policy and any person involved in either threatening or retaliation against a whistle-blower will be subject to disciplinary action(s). Employees who are harassed or victimized in any way are advised to report the matter to the person responsible for the investigation so that appropriate action may be taken.

7.3 A whistle-blower or any person who participated or intends to participate in an investigation arising from a Whistleblowing Report, who believes that he is subject to harassment/victimisation and that the Whistleblowing Report is a contributing factor to the harassment/victimisation may complain to the head Internal Audit (who shall refer the matter to the Audit Committee Chairman) or the Audit Committee Chairman. The Audit Committee Chairman shall review the matter and determine the actions to be taken.

8. External reporting mechanism

The objective of this Policy is to establish an internal mechanism for reporting and conducting an investigation and correcting any suspicious wrongdoings within MDC’s workplaces.

Whistleblowing concerns usually relate to the conduct of Employees. However. they sometimes involve actions committed by a third party. such as a customer, supplier or service provider to MDC. Employees are strongly advised to first internally raise any concern in good faith to one of the designated persons described in clauses 4.3 and/or 4.4. After raising their concerns. if Employee still reasonably believes that the third party is legally responsible. he/she may raise the concern in good faith with the relevant governing authorities. Unless required by law. Employees are advised to raise concerns internally in good faith. II’ in doubt. Employees should contact one of the designated persons designated in clauses 4.3 and or 4.4 for guidance in the first instance.

Please note that it is inappropriate for Employees to go to the media with a concern about suspected wrongdoings.

9. Seeking advice

Employees may discuss any matters regarding the Policy (without being required to make a formal report) with any of designated persons named in clauses 4.3 and/or 4.4.

The implementation of the Policy reinforces relevant guidelines and policies and is effective 1 July 2018.

How to handle the matter

• Employees are encouraged to report their concerns to their supervisor, who is in turn is responsible for promptly informing Head Internal Audit However, if the supervisor is of the view that the Head Internal Audit is, or may be, in a conflict of interest position, he/she may inform the Audit Committee Chairman, instead of the Head Internal Audit, about his/her concerns.

• If Employees prefer not to disclose the matter to their supervisor, they may report to the Head Internal Audit or Audit Committee Chairman.

• The Head Internal Audit shall promptly refer the Whistleblowing Reports to the Audit Committee Chairman.

• The Audit Committee Chairman will review the information disclosed, interview the Whistle-Blower(s) when required and, either exercising his own discretion or in consultation with the other Audit Committee members, determine whether the circumstances warrant an investigation and if so, the appropriate investigative process to be employed and corrective actions (if any) to take.