The Policy governs the reporting, investigation and deliberation of whistleblowing reports on alleged misconducts or unethical activities involving Maybank Investment Banking Group ("MIBG"). This Policy is intended to provide guidance to Directors, Employees as well as the general public on the concerns that are reportable and the avenues available for reporting.
OBJECTIVES OF THIS POLICY
The key objectives of the Policy are to:
- Provide an avenue and standards expected to be adhered to in dealing with reporting / disclosures by a Whistleblower;
- Promote a culture of openness, accountability, integrity and professional responsibility among Directors and Employees;
- Re-assure Whistleblower of protection against harassment, reprisals or victimization for raising genuine concerns;
- Provide management opportunity to address any corrupt, dishonest or fraudulent activities by implementing mitigating or remedial actions to prevent systemic collapse; and
- Deter potential offenders from engaging in fraudulent activities or misconducts, which could violate any laws, regulations, guidelines or policies.
The scope of the Policy includes, but not limited, to the following types of misconduct:-
- Any fraud, unlawful civil or criminal act;
- Any act of dishonesty, bribery, corrupt, abuse of power or authority for personal financial gain or any unauthorized purposes;
- Any breach of MIBG Policies, violation of any laws, rules and regulations governing the business and operations of MIBG; and
- Any malpractice or misdeeds, unethical and unlawful activity with regards to privileged information, material non-public information, market manipulation, rogue trading, market rigging, credit fraud, forgery, misappropriation of funds and/or assets , and any other unprofessional conduct that is a violation of laws, rules, regulations.
Disclosures can be made via any of the following channels:
Whistleblowing reports should at least contain the following basic information in order to proceed with the next course of action;
- Nature of misconduct;
- Names and designations of Directors or Employees involved;
- Name or account number of customers involved;
- Dates or period of the misconducts;
- Estimated amount involved (if possible); and
- Supporting documents/evidence in relation to the alleged transgressions (if available).
CONFIDENTIALITY AND PROTECTION OF WHISTLEBLOWER
MIBG assures that any disclosure report received from a Whistleblower will be kept strictly confidential and no adverse action will be taken against the Whistleblower as long as the report is made in good faith, without malicious intention or for personal gain.
MIBG is committed to protect any Whistleblower who has made a disclosure on wrongdoings involving other Directors or Employees or parties having dealings with MIBG.
AUDIT COMMITTEE OF THE BOARD (ACB)
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.