Objective
Whistleblowing is an important aspect of an accountability and transparency mechanism to enable personnel or business associates of PPB Group Berhad (“the Company”) and its subsidiaries (“the Group”) and members of the public to voice concerns in a responsible and effective manner.
It is a fundamental term of every contract of employment that a personnel of the Group will faithfully serve his or her employer and not disclose confidential information about the employer’s affairs. Nevertheless, where the whistleblowers discover information which they believe shows serious malpractice or wrongdoing within the organisation then this information should be disclosed internally without fear of discrimination or harassment.
The Whistleblower Protection Act 2010 (“the WPA”)
“An Act to combat corruption and other wrong doings by encouraging and facilitating disclosures of improper conduct in the public and private sector, to protect persons making those disclosures from detrimental action, to provide for the matters disclosed to be investigated and dealt with and to provide for other matters connected therewith.”
Essentially the WPA gives legal protection to a whistleblower against being dismissed or penalised by their employers as a result of disclosing serious concerns. The provisions of the WPA are to ensure that no whistleblower should feel at a disadvantage in raising legitimate concerns.
It should also be emphasised that this policy is intended to assist whistleblowers who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the Group nor should it be used to reconsider any matters which have already been addressed under harassment, complaint, disciplinary or any other procedures. Once the “whistleblowing” procedures are in place, it is reasonable to expect employees to use them rather than air their complaints outside the Group.
Scope of Policy
Any of the following persons (“whistleblower“) can make a report to the Company of any malpractice or impropriety:
This policy is designed to:
This policy covers not only possible improprieties in matters of financial reporting, but shall also include the following:
Principles
The Group will treat all such disclosures in a confidential manner. The identity of the whistleblower making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the whistleblower making the disclosure may need to provide a statement as part of the process or evidence required.
In the event the Group is faced with a circumstance where the identity is to be revealed, the Group will endeavour to discuss this with the whistleblower first.
Should the whistleblower choose to disclose his/her identity either internally or externally/ publicly, the Group is no longer obligated to maintain the confidentiality of the whistleblower.
This policy strongly encourages whistleblowers to put their name to any disclosures they make. However, whistleblowers may remain anonymous, if they choose to do so. Anonymous whistleblowers are encouraged to provide an email address or other contact information to facilitate proper investigation.
Whistleblowers are advised to provide sufficient information to enable the Group to conduct investigation. Additionally, the factors to be taken into account will include:
If a whistleblower makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the whistleblower should exercise due care to ensure the accuracy of the information. If, however, the whistleblower makes malicious or vexatious allegations, and particularly if he or she is an employee and persists with making them, disciplinary action may be taken against that employee.
How to Raise a Concern or Provide Information
Whom to report to:
You may report to any of the following :
(a) | Chair of the PPB Audit and Risk Committee | [email protected] |
(b) | Group Head of Internal Audit | [email protected] |
(c) | Group Head of Legal & Corporate Secretarial | [email protected] |
(d) | Company Secretary | [email protected] |
(e) | Group Chief Risk Officer (“GCRO”) | [email protected] |
(f) | Group Chief Human Resources Officer (“GCHRO”) | [email protected] |
How to make a report:
Investigating Procedure
The investigation process will be as follows:
If the whistleblower is not satisfied that his/her concern is being properly dealt with by the investigating panel, he/she has the right to raise it in confidence with the Audit Committee or one of the designated persons described above.
What happens after the investigation is completed?
Safe-keeping of Records
Oversight and Ownership of Policy
11 October 2024