Summary of Whistleblowing Policy
The objective of this Policy is to outline the framework for whistleblowing, providing a secure and confidential channel for all stakeholders of Malaysian Life Reinsurance Group Berhad (“the Company”) to raise concerns regarding improper conduct, unethical behavior, or questionable practices – without fear of retaliation.

 

Definitions 

• “confidential information” includes—

1. 1. information about the identity, occupation, residential address, work address or whereabouts of—
      1. a whistleblower; and
      2. a person against whom a whistleblower has made a disclosure of improper conduct;
   2. information disclosed by a whistleblower; and
   3. information that, if disclosed, may cause detriment to any person;

• “disciplinary offence” means any action or omission which constitutes a breach of discipline provided by law or in a code of conduct, a code of ethics or circulars or policy or a contract of employment, as the case may be;
• “improper conduct” means any conduct which if proved, constitutes a disciplinary offence or a criminal offence;
• “whistleblower” means any person who makes a disclosure of improper conduct to the Company and/or relevant authorities, and shall include employees, the public and other parties such as former employees, temporary or contract employees, consultants, contractors, vendors and clients;
• “whistleblower protection” means protection conferred to a whistleblower under this Policy;
• “whistleblowing” is a way by which any one can report or disclose improper conduct, unethical or unlawful behavior that has been done or is being done in the Company. Whistleblowing is a way to alert the Company and/or relevant authorities that stakeholders are being wrongfully harmed or they are at the risk of harm.

 

Whistleblowing channels
Whistleblowing channels serve as the initial point of contact for individuals to report concerns regarding improper conduct within or related to the Company.

If any stakeholders reasonably and in good faith believes that misconduct has occurred in the Company, they are required to report the matter immediately and directly to the Company’s Audit Committee Chairman (“AC Chairman”) via the following channels:

• E-mail: whistle@mlre.com.my; or
• Official letter addressed to the AC Chairman and sent to the Company’s registered address.

Note: In the event that the report received contains reasonable suspicion of an offence under the laws of Malaysia, the same shall be transmitted   in strictest confidence, to relevant external enforcement agencies such as Bank Negara Malaysia (BNM), Royal Malaysia Police (PDRM) and Malaysian Anti-Corruption Commission (MACC) for further action.

Individuals who choose to remain anonymous are advised that the Company’s ability to thoroughly investigate the reported misconduct may be limited by the information provided. If the report lacks sufficient detail, the Company reserves the right not to proceed with an investigation, as anonymity may prevent necessary clarification for a proper investigation.

 

Whistleblower protection
The whistleblower shall be protected against the following actions for raising allegations of misconduct even if the allegations has been proven to be incorrect or unsubstantiated:

a. Protection of confidential information; and

b. Protection against detrimental action.

The same level of protection shall be extended to any person related to or associated with the whistleblower.

All whistleblowing reports have to be made in good faith with reasonable belief that the information and allegation is true, not frivolously/maliciously made, and not for personal gain; otherwise, the Company reserves the right to take action against the whistleblower.

 

Whistleblower protection under the Whistleblower Protection Act 2010
The protections provided under the Act are only applicable when disclosures are made in good faith and directed to the relevant enforcement authorities such as the MACC, PDRM, BNM and other designated government agencies. Disclosures made to the media, the public, or on social media platforms are not protected under the Act.

 

Regulators / External agencies
The whistleblower is not refrained from communicating with regulators / external agencies as a recourse relating to the disclosure of reportable conduct particularly in the following circumstances:

a. When it is believed that the disclosure may not have been taken seriously or addressed as appropriate by the Company;

b. Whistleblower is dissatisfied with the outcome of the investigation process;

c. Whistleblower is unfairly treated or victimized.

Contact details of external enforcement agencies (this list is not exhaustive):

• Bank Negara Malaysia (BNM) (www.bnm.gov.my)
  i. Director of LINK via Email: directorlink_wb@bnm.gov.my
• Malaysian Anti-Corruption Commission (MACC) (www.sprm.gov.my)
  i. Online Complaint Management System (CMS): www.portaladuan.sprm.gov.my
  ii. MACC Hotline: 1-800-88-6000