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Maybank Securities Whistleblowing Policy

  1. Policy Statement

    Maybank Securities Pte Ltd ("MSSG") is committed to the highest standard of ethics and integrity in its conduct of business and operations. As part of this commitment, MSSG has in place an avenue for disclosure of any improper conduct.

  2. Objectives of This Policy

    The objective of this policy is to ensure that all employees and members of the public have access to secured channels to make disclosures on any improper conduct by any member or representative of MSSG, with the assurance that there will be no repercussion against them so long as the report are made in good faith.

  3. Scope

    Improper conduct includes, but is not limited to:

    1. Bribery and corruption;
    2. Fraud, theft or embezzlement;
    3. Abuse of power by an employee;
    4. Conflict of interest;
    5. Breach of MSSG policy and procedure;
    6. Failure to comply with legal and regulatory obligations;
    7. Unauthorised disclosure of customer information;
    8. Breach of MSSG Code of Conduct; and
    9. Concealment of any of the above.

    Any person who is aware of, or has reasonable grounds to suspect that, any improper conduct has been committed by an employee or representative of MSSG can make a disclosure.

  4. Disclosure Channels

    Disclosures can be made via phone, in person and/or in writing (physical or electronic) to any of the following Designated Recipients ("DR"):

    Reporting Level Designated Recipients
    Maybank Securities Pte Ltd ("MSSG")

    (Only applicable for whistleblowing reports concerning and/or relating to MSSG)
    1. Head of Compliance;
    2. Head of Internal Audit;
    3. Chairman of the Board of Directors;
    4. Any independent member of the Board of Directors or member of the Audit Committee
    Maybank Investment Banking Group ("Maybank IBG")
    1. Chief Compliance Officer, Maybank IBG;
    2. Head of Internal Audit, Maybank IBG;
    3. Chairman of the Board of Directors at Maybank IBG Holdings Limited;
    4. Any Independent member of the Board of Directors or member of the Audit Committee of Maybank IBG Holdings Limited.
  5. Whistleblowers are encouraged to include the following information in the disclosure to facilitate investigations:

    1. Name of person(s) involved;
    2. Date and time of the event;
    3. Nature of the event;
    4. Witness to the event, if any; and
    5. Evidence of the event, if any.
  6. Confidentiality and Protection of Whistleblower

    The identity of a whistleblower who made a disclosure in good faith will be kept confidential and will only be disclosed on a strictly need-to-know basis. Employees who whistleblow in good faith will also be protected by MSSG from any repercussion.

  7. Deliberation of Whistleblowing Reports
    1. Any whistleblowing reports received by DRs will be required to be escalated Maybank IBG Compliance team for investigation. However, if the reports are made against the Chief Compliance Officer, Maybank IBG, the respective DR receiving the whistleblowing report may escalate the report to Maybank IBG Internal Audit to conduct the investigation.
    2. Upon completion of the investigation, Maybank IBG Compliance / Internal Audit will escalate to the Audit Committee of the Board ("ACB") at Maybank IBG for deliberation.
    3. The ACB is chaired by an Independent Non-Executive Director and provides avenue to ensure that any reports or disclosures made via the whistleblowing channels are accorded with adequate attention, independence, investigation and remedial action, where necessary.