OBJECTIVE

The Bank is committed to achieve the highest standard of service and ethical in all its business, activities and practices.

The Whistleblowing Guidelines & Procedures (the Guidelines) are intended to provide a means to all employees and third parties who have discovered malpractice or impropriety and feel unable or uncomfortable to raise the concern through the normal reporting channels, to report the concern directly to the Designated Officers and to offer protection from reprisals in view of the reported allegation.

SCOPE

• Improprieties in matters of financial reporting.
• Suspected fraudulent activity.
• Conduct of activity which breaches any law or regulatory obligation.
• Breaches of the Bank’s policies, procedures, practices or other rules of conduct
• Deliberate concealment of information tending to show the malpractices or misconducts.
• Retaliation or reprisal against an employee / third party who reports a misconduct / wrongdoing.

CONFIDENTIALITY

The Bank is committed to ensure that all information are disclosed in good faith, including the identity of the whistleblower, is treated with strictest confidentiality unless the identity of the whistleblower is needed to be revealed under the provisions of law / regulations.

The whistleblower shall not discuss details of the reported misconduct/wrongdoing or related investigation with anyone other than the Designated Officers, unless specifically requested to do so by the Designated Officers or required by law and / or regulation (i.e. in a regulatory investigation or court hearing).

PROTECTION FROM RETALIATION OR REPRISAL

The Bank will accord protection to the whistleblower on confidentiality of identity, to the extent reasonably practicable.

Staff who raises issues or concerns in good faith and in accordance with the methods described in the Guidelines will be protected from retaliation.

This protection will cease to be applicable if requirements under the Guidelines are not adhered to (e.g. the whistleblower was involved in improper conduct or was found to have made disclosures in bad faith).

REPORTING PROCESS AND CHANNELS OF COMMUNICATION

The whistleblower shall report the misconduct / wrongdoing in good faith (either verbally or through written communication) to the Designated Officers by:

• Providing information at hand and details of the reported misconduct/wrongdoing, such as:
  1. Date of the incident
  2. Nature / description of the misconduct / wrongdoing
  3. Name of person(s) involved in the misconduct / wrongdoing
  4. Witnesses to the misconduct / wrongdoing, if available
  5. Supporting evidence and / or documents of the misconduct / wrongdoing, if available
• Meeting any reasonable request to clarify any facts and / or circumstances.
• Providing all relevant and additional information
• Being available for and cooperate with the investigation.
• Respecting confidentiality.

CONSEQUENCES OF BREACHES

A whistleblower who has not acted in good faith by reporting an alleged misconduct / wrongdoing under the Guidelines or who does not respect the confidentiality provisions of the Guidelines:

• may lose the rights and protections provided under the Guidelines; and
• may be subjected to disciplinary action, criminal prosecution and / or civil liability.

OTHER AVENUES FOR WHISTLEBLOWING

Other avenues for whistleblowing to regulators or law enforcement agencies include, among others, Bank Negara Malaysia (BNM), Malaysian Anti-Corruption Commission (MACC) and the Royal Malaysia Police.