Whistleblowing Policy

Bank Pembangunan Malaysia Berhad Group (BPMB Group) consists of Bank Pembangunan Malaysia Berhad, Pembangunan Leasing Corporation Sdn. Bhd. (PLC), Global Maritime Ventures Berhad (GMV), Small Medium Enterprise Development Bank Malaysia Berhad (SME Bank), and Export-Import Bank of Malaysia Berhad (EXIM Bank).

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 all Directors of BPMB Group, Shariah Committee, senior management, employees and any other persons who have established relationship with BPMB Group (refer to Associated Persons1). It includes but is not limited to customers/borrowers, potential customers/borrowers, agents, consultants, Public/Government Officials (refer to Business Associates) and Third Parties as well as members of the public.

Protection to Whistleblower

BPMB Group is committed to provide protection (to the extent reasonably practical) to the whistleblower provided that the disclosure was made in good faith. This includes the confidentiality of identity, immunity from civil or criminal action and protection against any detrimental action against the whistleblower. Should the whistleblower encounter any retaliation, harassment or demotion arising from the whistle blowing, an immediate report needs to be made to Chairman of BOD or Chairman of GBAC or Chairman of GWBC.

Additionally, the whistleblower may also make complain to the relevant enforcement authority of any detrimental or reprisal action committed by any person against him, where relevant.

The Bank has the right to revoke the protection to the whistleblower should the following incidences is discovered:

• The whistleblower himself has participated in the improper conduct disclosed;
• 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 whitleblower, in the course of making the disclosure or providing further information, commits an offence under Whistleblower Protection Act.

The identity of the whistleblower shall at all times remain with the Designated Whistleblowing Director (Chairman of the Board and Chairman of GBAC) or Chairman of Group Whistleblowing Committee (GWBC) or CIGO whom had received the disclosure.

How to Whistleblow

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

Type of concerns and disclosure of concerns:

Concerns falling under the scope of this Whistleblowing Policy and that can be reported through whistleblowing including, but not limited to:

• The act of corruption, rribery, or blackmail;
• The act of fraud, theft or embezzlement;
• The act of bullying or harassment;
• Abuse of power and/or uuthority;
• 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.

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

Other alternative, the whistleblower may contact Deloitte Halo 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.