1.1 Safetyware Sdn Bhd and all its subsidiary (“Safetyware Group”) expects all employees of Safetyware Group to act at highest standard of professional integrity in the conduct of its businesses and operations and to comply with all applicable law, regulations and internal policies. Safetyware Group recognize that upholding the standard, a proper avenue needs to be provided for all employees of Safetyware Group and external parties to disclose any improper conduct within Safetyware Group.
2.1. This Policy forms an integral part of Safetyware Group’s commitment towards promoting a culture of integrity and transparency within Safetyware Group.
2.2. This Policy is to provide a proper and confidential channel for employees, agents or office bearer of Safetyware Group and/or external parties to report or raise legitimate concerns in regards to any illegal, unethical or improper conduct and/or fraudulent practices without the risk of reprisal.
2.3. By this Policy, Safetyware Group seeks to encourage the reporting of any illegal, unethical or improper conduct and/or fraudulent practices by employees, agents or office bearer of Safetyware Group and external parties of which they become aware so that damage control or remedial action can be taken promptly.
3.1. This Policy applies to all employees, agents or office bearer of Safetyware Group, external parties such as clients, suppliers, vendors, contractors, sub-contractors, consultants and other stakeholders including members of the public who have dealings with Safetyware Group.
3.2. This Policy shall cover all reports made against any employee that has committed an improper conduct. The scope of this Policy shall include illegal, unethical or improper conduct as follow: -
- Any act of dishonesty, abuse of power or authority for personal financial gain
- Conflict of interest
- Any violations of relevant laws, rules and regulations
- Any unethical behaviour
The above list is not exhaustive and includes any act or omissions, which if proven, will constitute an act of misconduct under the Code of Conduct and Ethics of Safetyware Group or any criminal offence under relevant legislations in force.
4.1. Any disclosure of improper conduct must be in writing and made to the relevant Designated Person through any of the communication channels as set out below: -
In writing and mail/hand deliver to:
Mr Wong Kee Wei
Safetyware Sdn Bhd
Plot 237, Lengkok Perindustrian Bukit Minyak 3
Bukit Minyak Industrial Estate
14100 Simpang Ampat Penang
or by email to “firstname.lastname@example.org”
A whistleblower shall be accorded with protection of confidentiality of its identity, to the extent reasonably practicable. Whistleblowers are encouraged to provide their identity to enable further information or clarification is able to be obtained for purpose of investigation into the improper conduct.
In any event where a whistleblower elects to remain anonymous, all dealings with the whistleblower’s disclosures will be handled in such a manner so as to preserve the anonymity of the whistleblower, where possible. However, it is advised that the matter may not be properly investigated and responded to due to limitation of the contents of the disclosure received. Whilst anonymous submissions/advices are not encouraged they will still be accepted.
You may make a report anonymously but are encouraged to identify yourself to assist with the investigation. If you have asked to remain anonymous, every effort will be made to keep your identity confidential, at least until any formal investigation is in progress. In order not to jeopardize the investigation into the alleged improper conduct, you will also be expected to keep the fact that you have raised a concern, the nature of the concern and the identity of those involved confidential.
Whistle blowers advising incidents of improper conduct shall be protected from harassment or reprisals as a consequence of their disclosure. When a disclosure is received, and an investigation commences, Safetyware Group will appoint a Whistle Blower Welfare Officer (“WBWO”) who will usually be the Group General Manager – Human Resources. The WBWO will not be involved in investigating the disclosure. Rather, he or she will focus on assisting and supporting the whistle blower and liaising with them regarding the investigation.
You are encouraged to make a disclosure of any conducts or acts that you genuinely believe may be dishonest, fraudulent, corrupt, illegal, bullying or harassing, represent a serious conflict of interest, involve a misuse of sensitive or confidential information or a miscarriage or denial, or likelihood thereof, of natural justice.
As it is essential for Safetyware Group to have critical information in order to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The complaint should include details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible, and contact details, in case further information is required.
All matters reported will be reviewed within a reasonable timeframe, and after due consideration and inquiry, a decision will be taken on whether to proceed with a detailed investigation. Guidance/direction may be sought from Managing Director and other appropriate parties. All complaints received by the Managing Director will be reported to the Audit Committee, Safetyware Group Managing Director and the Chairman of the Board of Safetyware Group (“collectively, Investigation Committee”).
Safetyware Group reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Directors and employees of Safetyware Group who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.
If at the conclusion of an investigation, the Investigation Committee determines that a violation has occurred, or the allegations are substantiated, a corrective action and/or disciplinary action to be taken shall be decided by the Board of Safetyware Group.
As and where applicable, the management of Safetyware Group shall recommend such appropriate controls to prevent and/or minimize the risk of the recurrence of any improper conduct which has been uncovered.
10.1 Safetyware Group prohibits discrimination, retaliation or harassment of any kind against a whistle blower who submits a complaint or report in good faith. If a whistle blower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the Managing Director. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.
10.2 Safetyware Group will treat all disclosures of improper conduct seriously and protect employees who raise concerns in good faith. However, appropriate disciplinary action will be taken against any employee who is found to have made a disclosure maliciously that they know to be untrue, or without reasonable grounds for believing that the information supplied was accurate. This may result in dismissal.
10.3 At the appropriate time, the party making the report/complaint may need to come forward as a witness. If an employee or an external party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. However, if an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the external party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.
11.1 Safetyware Group reserves the right to modify and/or revised this Policy from time to time.