Whistleblowing Policy

Bank Pembangunan Malaysia Berhad Group (BPMB Group) consists of Bank Pembangunan Malaysia Berhad, Pembangunan Leasing Corporation Sdn. Bhd. (PLC) and Global Maritime Ventures Berhad (GMV).

BPMB Group is committed to the highest standards of ethical, integrity, accountability and legal conduct.

BPMB Group is committed to uphold the Malaysia’s Anti-Corruption Principles in promoting integrity, transparency and good governance in all aspects of its operation upon signing the Corporate Integrity Pledge.

Objective of the Policy

The Whistleblowing Policy is intended to assist individuals to whistleblow their concerns which they have discovered and to provide protection to the whistleblower, in-line with the protection accorded by the Whistleblower Protection Act 2010.

Applicability

Applicable to directors, staff, subsidiaries and any other persons where BPMB Group has established relationship including, but not limited to, agents, consultants, suppliers, vendors and service providers. Member of the publis are also encouraged to whistleblow should they have discovered any concerns pertaining to BPMB Group’s practice.

Protection to Whistleblower

1. BPMB Group shall provide protection (to the extent reasonably practical) to the Whistleblower provided that the disclosure is made in good faith. This may include, for example, the provision of physical security, interim accommodation arrangements or restitution etc., all of which are subject to BAC’s approval.
2. A Whistleblower protection conferred under this Whistleblowing Policy is not limited or affected in the event that the disclosure of improper conduct does not lead to any disciplinary action or prosecution of the person against whom the disclosure of improper conduct has been made.
3. The cited Whistleblower Protection Act 2010 does not limit the protection conferred by any other written law to any person in relation to information given in respect of the commission of an offence.
4. In the event the Whistleblower encounters any retaliation, harassment or demotion arising from the whistleblowing, an immediate report needs to be made to Chairman of the Board or Chairman of BAC or Chairman of WBC. Additionally, the Whistleblower may also make a report to the relevant enforcement authority i.e. PDRM, MACC or others LEA of any Concern and/or of any detrimental or reprisal action committed by any person against him, where relevant.
5. The identity of the Whistleblower shall at all be kept confidential and shall remain with the Chairman of the Board, BAC, WBC and EIP.

Revocation of Whistleblower Protection

1. The Whistleblower protection stated above shall be revoked if it is of the opinion based on its investigation that:
   • The Whistleblower himself has participated in the improper conduct disclosed;
   • The Whistleblower wilfully made in his disclosure of improper conduct a material statement which he knew or believed to be false or did not believe to be true;
   • The disclosure of improper conduct is frivolous (i.e. not having any serious purpose or value) or vexatious (i.e. causing or tending to cause annoyance or frustration);
   • The disclosure of improper conduct principally involves questioning the merits of government policy, including policy of a Public Body;
   • The disclosure of improper conduct is made solely or substantially with the motive of avoiding dismissal or other disciplinary action; or
   • The Whistleblower, in the course of making the disclosure or providing further information, commits an offence under Whistleblower Protection Act 2010.
2. A written notice shall be given to the Whistleblower if the protection is revoked. BPMB Group reserves the right to take appropriate action as necessary per BPMB Group’s internal policies and procedures.
3. Any person aggrieved by the decision of BPMB Group may refer the decision of BPMB Group to the enforcement agencies i.e. PDRM and MACC for further investigation.
4. The court may make an order for the preservation of the Whistleblower protection and may also make such consequential orders necessary to give effect to the order for relief.

How to Whistleblow

BPMB Group takes whistleblowing very seriously and will review all reports and initiate an investigation where possible. Reports are completely confidential.

BPMB Ethics Line is designed to receive disclosures relating to the listed below:

1. Scope of Whistleblowing

• The Act of Corruption, Bribery, or Blackmail;
• The Act of Fraud, Theft or Embezzlement;
• The Act of Bullying or Harassment;
• Abuse of Power and/or Authority;
• Breach(es) of Applicable Laws & Regulations
• Breach(es) of BPMB Group’s Policies and/or Procedures;
• Conflict of Interest Situations;
• Illegal Activities and Criminal Offences;
• Misconduct or Miscarriage of Justice;
• Misuse of BPMB Group’s Property;
• Any other Concerns that May Expose BPMB Group to Reputational Risks in Case of Public Disclosure; and
• Concealment or Abetment of Any of the Above.

2. Matters which do not fall under the scope mentioned above shall be categorized as grievances i.e. discipline, demotion, improper classification or denial of earned overtime etc. and do not fall under the ambit of the Whistleblowing Policy.

The Whistleblower can make a disclosure in writing containing the background and history of the concerns, the names of the persons involved, where and when the concerns took place and other relevant information to assist the investigation along with supporting evidence, if available. To ensure completeness of the required information, whistleblower is encouraged to use the whistleblowing form which is made available in BPMB Group’s website.

The disclosure shall be made in writing (sealed mail or e-mail) to any of Director and Management.

Other alternative, the whistleblower may contact BPMB Ethics Line which it is an independent whistleblowing service managed by Deloitte on behalf of BPMB Group.

Members of the public are also encouraged to whistleblow should they have discovered any incidences above, where relevant.