WHISTLEBLOWING POLICY
1. Introduction
If any employee believes reasonably and in good faith that malpractice exists in the work place, the employee should report directly to his/her immediate superior All employees are encouraged to raise genuine concerns about possible improprieties in matters of financial reporting, compliance and other malpractices at the earliest opportunity, and in the appropriate way.
This policy is designed to:
– Support the company’s values
– Ensure employees can raise concerns without fear of reprisals; and
– Provide a transparent and confidential process for dealing with concerns
This policy not only covers possible improprieties in matters of financial reporting, but also:
– Fraud
– Corruption, bribery or blackmail;
– Criminal Offences:
– Failure to comply with legal or regulatory obligations:
– Miscarriage of justice:
– Endangerment of an individual’s health and safety: and
– Concealment of any or a combination of the above.
2. Principles
The principles underpinning the policy are as follows:
– All concerns raised will be treated fairly and properly:
– The company will not tolerate harassment or victimisation of anyone raising a genuine concern;
– Any individual making a disclosure will retain anonymity unless the individual agrees otherwise:
– The company will ensure no one will be at risk of suffering some form of reprisal as a result of raising a concern even if the individual is mistaken. The company, however, does not extend this assurance to someone who maliciously raises a matter he/she knows is untrue.
3. Grievance Procedure
In our commitment to hold high standards of ethical, moral and legal business conduct, a grievance procedure had been established. This procedure shall address enquiries and grievances from internal and external stakeholders with transparency and accountability to all parties involved in a fair and timely manner.
Grievances are classified in 2 categories – Internal Stakeholders and External Stakeholders and shall be handled in accordance to the category
Internal Stakeholder
Step One
The employee should resolve disputes and minor problems amicably and informally between themselves with their immediate supervisors for production employees or department heads for office employees within three (3) working days.
However, if for any reason the employee is reluctant to report to immediate supervisors, then the employee should report the concerns to:
1. syedmohamadaidid@gmail.com ( Group Executive Chairman’s Office )
2. SrIndependentDir@master.net.my (Senior Independent Director)
3. hrmpgb@master.net.my (Group HR Department Head)
4. Write the grievance in a letter and put it in the Suggestion Box
Employees who have raised concerns internally will be informed of who is handling the matter, how they can make contact with them and if there is any further assistance required.
Employees’ identities will not be disclosed without prior consent. Where concerns cannot be resolved without revealing the identity of the employee raising the concern i.e. where the evidence is required in court, a dialogue will be carried out with the employee concerned as to whether and how the matter can be proceeded.
Step Two
If the employee fails to obtain satisfaction for his/her grievance within three (3) working days of reporting step one, he /she may report the grievance in writing via letter or email to the Factory/ Plant Manager for production employees or to the General Manager/ Executive Director Assistant for office employees.
Step Three
The Plant Manager/ General Manager /Executive Director shall then nominate an independent person together with a representative from HR for the grievance case to be heard. Interviews and inquiries into the case shall be carried out within 10 to 14 working days from date receiving email from General Manager/ Executive Director. to hold interviews/ inquiries
In the event the employee does not cooperate in the midst of the investigation or the employee leaves the Company, the case shall continue in the absence of the employee base on what limited evidence is available in order to close the case.
A case report on the findings and proposed solutions and actions to be taken shall be completed and tabled for the top management decision. The employee is informed of the outcome and the remedial action taken to solve the grievance.
Protection Against Grievance
Every grievance shall be treated with strict confidentiality and the employee shall be safeguarded from unwarranted retaliations. There is no repercussion or punitive action against the employee for reporting grievances.
If the employee decides to withdraw the grievance at any stage of the investigation, he/she has to write formally to the HR personnel his/her decision to withdraw the case invoke.
Although employees’ have a right to raise a grievance, the employee is expected to act in good faith. If the grievance made is proven after investigation or inquiry to be malicious or the employee reported with wilful dishonesty and bad faith, the Company reserves the rights to take the appropriate disciplinary actions against the employee.
External Stakeholder
Step One
Grievance received from external stakeholders by Department Heads are to be recorded in writing at the point of receipt.
The lodgement of grievances is to be recorded in writing and send/ emailed to either .
1. syedmohamadaidid@gmail.com ( Group Executive Chairman’s Office )
2. SrIndependentDir@master.net.my (Senior Independent Director)
3. hrmpgb@master.net.my (Group HR Department Head)
Step Two
A case file shall be open and an Investigation Team consisting 3 to 5 people selected to investigate the reported grievance within 10-14 working days. The investigation report together with a proposed solution shall be tabled to the top management or Executive Committee
Step Three
Decision on grievance and action taken is recorded and the stakeholder is informed accordingly of action taken for the grievance case reported. In the event the case is unsettled / delayed in finalizing, the external stakeholder shall be kept informed of the progress status.
The top management or Executive Committee may at its own discretion seek professional legal advice to resolved the matter, in the event the need should arise
The Whistleblowing Policy shall be reviewed by the Board of Directors every three (3) years or as required by the Company and the Group.