SECTION 1.0 POLICY STATEMENT
Percetakan Nasional Malaysia Berhad (PNMB Group) is committed to the highest standard of integrity, openness and accountability in the conduct of its businesses and operations. It aspires to conduct its affairs in an ethical, responsible and transparent manner.
Recognising the above-mentioned values, PNMB Group provides an avenue for all PNMB personnel and members of the public to disclose any improper conduct within the Company.
SECTION 2.0 OBJECTIVE
This policy is to encourage and provide an avenue for all personnel, customers and vendors to disclose any improper conduct in accordance with the procedures as provided for under this policy and to provide protection for PNMB personnel and members of the public who report such allegations.
SECTION 3.0 SCOPE
3.1 The confidential disclosure may be made through the Whistleblowing Channel within the PNMB Group as set out in this Policy or to the relevant regulatory authorities or enforcement agencies. Disclosures to the regulatory authorities or enforcement agencies will be governed by the Whistleblower Protection Act 2010 or the relevant acts, as applicable. The provisions in this Policy only relate to disclosures made through the whistleblowing channel within the PNMB Group.
3.2 If a PNMB personnel is unsure whether a particular act or omission constitutes improper conduct under this Policy, the personnel is encouraged to seek advice or guidance from the Head of Risk Management, Compliance, Integrity & Audit Department.
SECTION 4.0 APPLICABILITY
This Policy applies to all Directors and employees of PNMB Group (collectively referred to as “Personnel”). It is also expected that all bidders, business partners, contractors, consultants, business associates or other service providers including their employees, contractors, agents and related entities providing goods and/ or services to PNMB Group, comply with the relevant parts of this Whistleblowing Policy when performing such work or services.
SECTION 5.0 LIMITATIONS
This Policy does not, however, cover any issues, complaints or concerns to:
a) Matters which are trivial or frivolous in nature; and
b) Matters which are motivated by malice.
If the complaint is a grievance and not an Improper Conduct, the Grievance Policy and Procedure in the Employee Handbook of the Company or respective Subsidiary is to be applied. For Improper Conduct relating to sexual harassment, the Sexual Harassment Policy of the Company or respective Subsidiaries is to be applied.
SECTION 6.0 IMPLEMENTATION PROCEDURES
6.1 Every complaint, report or information can be channelled via mail, email, telephone or a face-to-face meeting. It is imperative where possible that a meeting with the complainant be made to ensure the credibility and validity of the information received.
6.2. The Whistleblowing Channels available include the following:
i) Email the report to [email protected]; or
ii) To submit written letters to the Tradewinds Group (M) Sdn. Bhd. (TGM)
Attention to:
Whistleblowing Council Channel
Tradewinds Group (M) Sdn. Bhd.
Level 4A, No. 88 Jalan Perdana,
Taman Tasik Perdana,
50480 Kuala Lumpur.
(Please refer to Appendix A – Whistleblowing Form)
6.3 The disclosure should include:
i) His/her name in the form, as disclosure expressed anonymously is much less credible, but will nonetheless be considered.
ii) Description of the improper conduct and the people/parties who are involved.
iii) Background of the incident, including the relevant dates and location of occurrence.
iv) How improper conduct was detected.
v) Reason(s) why the Whistleblower is particularly concerned about this (e.g. it may result in loss of the Group’s assets/funds).
vi) Particulars or production of documentary evidence and witnesses, if any.
6.4 It will be the task of the Investigation Team to assess, investigate and report on the complaint to the Management and recommend a course of action promptly and fairly.
6.5 The Whistleblower shall not:
i) Contact the suspected personnel(s) to determine facts or demand restitution; and
ii) Discuss the case, facts, suspicions or allegations with anyone except with the Investigation Team.
SECTION 7.0 TRADEWINDS GROUP (M) SDN BHD’s WHISTLEBLOWING COUNCIL
Tradewinds Group (M) Sdn Bhd (‘’TGM’’)’s Whistleblowing Council (“WB Council”) as a part of the TGM’s efforts to ensure accountability and transparency over whistleblowing reports on improper conducts disclosed by employees, stakeholders and business partners.
The WB Council’s responsibilities cover the following companies:
a) TGM;
b) Tradewinds Plantation Berhad;
c) Padiberas Nasional Berhad;
d) Central Sugars Refinery Sdn Bhd
e) Tradewinds Corporation Berhad, and
f) Other wholly owned subsidiaries of TGM.
Companies in items (b), (c), (d), (e) and (f) are collectively referred to as “the Subsidiaries”.
SECTION 8.0 PROTECTION TO WHISTLEBLOWER
8.1 Whistleblowers who is a PNMB Group personnel will be protected from any reprisal as a direct consequence of the disclosure subject to the conditions fulfilled as in point 8.3. (‘Reprisal’ means disciplinary measures, demotion, suspension, termination of employment or service or any other retaliatory action). If the alleged wrongdoing is not subsequently proven, the Whistleblower will also be protected from reprisal subject to the conditions fulfilled as in point 8.3.
8.2 Suppliers and vendors of PNMB Group and members of the public who become Whistleblower will also be protected by PNMB Group as to his/ her identity subject to the conditions fulfilled as in point 8.3.
8.3 Protection to the Whistleblower will be accorded by PNMB Group only when the Whistleblower satisfies all the following conditions:
i) The disclosure is done in good faith and is not frivolous or vexatious or is not made with malicious intent or ulterior motive.
ii) The whistleblower has disclosed his/her identity and contact details.
iii) The Whistleblower has not communicated the disclosure to any other party not related to the disclosure.
iv) The disclosure made is not for personal gain or interest.
8.4 The personnel who make allegations or reports that prove to have been made without good faith will be subject to disciplinary action (which may include termination of employment). In the case of customers, suppliers, subcontractors or consultants, the continuity of business relationship shall be reviewed.
8.5 Any form of retaliation undertaken by personnel against any Whistleblower for reporting an irregularity in good faith is prohibited and considered to be in breach of the Company’s Policy and Procedures. In such cases, disciplinary measures shall be taken against the said personnel. Disciplinary action may include termination.
8.6 The personnel who consider that they have been the victim of retaliation for reporting an irregularity or have good reason to believe or fear that they are exposed to the risk of retaliation as a result of their reporting an irregularity shall report the matter to the Head of Risk Management, Compliance, Integrity & Audit Department and request that protective measures be adopted. The protection against retaliation shall be extended to any other party associated with the personnel.
SECTION 9.0 COMMUNICATION & NOTIFICATION
9.1 During the investigation stage, information on the case shall be restricted only to those who need to know of the matter, i.e. on a need-to-know basis. If necessary, the Marketing & Communications Team shall be roped in to prepare an appropriate statement for release to the public.
9.2 The personnel involved shall be reminded to preserve the confidentiality of the matter.
9.3 The required announcement(s) as required by the regulatory authorities shall be made accordingly in compliance with the disclosure requirements of the relevant regulations.
9.4 Upon the completion of the whistleblowing process and procedures, the whistleblower will be accorded the privilege of being notified of the disclosure outcome.