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Whistleblowing Policy



  1. Introduction

    MNRB Group is committed to carrying out its business in accordance with the highest standards of professionalism, honesty, integrity and ethics. Accordingly, the Group has established a Whistleblowing Policy (“the Policy”) with the following intended objectives:

    a.To have in place culture of accountability and integrity within the Group;
    b.To provide a safe and confidential avenue for directors, employees, and other parties to raise concerns about any unacceptable practice or misconduct;
    c.To reassure whistleblowers that they will be protected from detrimental action or unfair treatment for disclosing concerns in good faith; and
    d.To deter wrongdoing and promote standards of good corporate practices.
  2. Scope
    This Policy governs the disclosures, reporting and investigation of misconduct within the Group as well as the protection offered to the person(s) making those disclosures (“Whistleblower(s)”) from detrimental action in accordance with Act 711, Whistleblower Protection Act 2010 (“the Act”). The scope of the policy applies to MNRB Group’s directors, employees and other parties. This Policy supersedes other policies of the Group in terms of execution including procedures relating to grievances and complaints, job performance, terms and conditions of employment or disciplinary procedures.

    For the purpose of this Policy, references to directors shall include Group Shariah Committee Members.

  3. Definitions
    i.MNRB - MNRB Holdings Berhad
    ii.MNRB Group / the Group - MNRB and all its subsidiaries
    iii.Other Parties - Other parties include intermediaries, vendors, consultants, and other stakeholders.
    iv.Whistleblower - A person or entity making a disclosure about improper or illegal activities. Whistleblower may include all directors, employees, and other parties.
    v.Designated Recipients - Recipients of whistleblowing disclosures
    vi.Misconduct - Misconduct connotes improper activity that include, but are not limited to:
    1. a suspected criminal offence;
    2. contravene any of the requirements and standards of a regulatory body, shariah principle (for Takaful and Retakaful), professional body, government or its agencies;
    3. impropriety, corruption, acts of fraud, theft and/misuse of the Company’s properties, assets or resources;
    4. abuse of power or authority;
    5. conflicts of interest without disclosure;
    6. sexual harassment;
    7. bribery, blackmail and miscarriage of justice;
    8. attempts to suppress or conceal any information relating to any of the above; and
    9. inethical business practice.
    vii.Good Faith - Good faith is evident when the disclosure is made without malice or consideration of personal benefit and the Whistleblower has a reasonable basis to believe that the allegation is true; or reasonably substantiated evidence tendered. Good faith is lacking when the disclosure is reasonably verified as mala fide, frivolous, malicious, vindictive or baseless.
  4. Protection for Whistleblower
    It is the Group’s policy to encourage its directors, employees and other parties to disclose any misconduct, and to fully investigate disclosures of such misconduct. The Group shall provide the Whistleblower protection in terms of confidentiality of information, and safeguard the Whistleblower from any act of interference that may be detrimental to the Whistleblower. The Group assures that all disclosures will be treated with strict confidentiality and prompt investigation will be carried out.

  5. Roles and Responsibilities
    1. Board of Directors
      The Board shall :
      i.oversee that there are adequate resources available to address all concerns raised by the Whistleblowers and that they are properly investigated and appropriate actions taken; and
      ii.guarantee the protection of Whistleblowers if the disclosure is made in good faith and in accordance with this Policy.
    2. Senior Management
      The senior management will implement this Policy and promote it across the Group by fostering and maintaining an environment where Whistleblowers can act appropriately, without fear of retaliation.

    3. Recipient of Disclosure
      Any disclosure of improper conduct must be made to any of the relevant designated recipients through the communication channels as set out in the table below:

      Disclosure Matrix for Whistleblowing

      Category 1:

      For disclosure against:
      1. MNRB’s Chairman of the Board;
      2. Any Director; or
      3. Any Shariah Committee Member

      Designated Recipient:
      MNRB’s Chairman of Audit Committee
      Official email:

      Category 2:

      For disclosure against:
      1. MNRB’s Chairman of Audit Committee; or
      2. President & GCEO

      Designated Recipient:
      MNRB’s Chairman of the Board
      Official email:

      Category 3:

      For disclosure against:
      1. Chief Executive Officers;
      2. Senior Management;
      3. Employees; or
      4. Other Party

      Designated Recipients:
      1. MNRB’s Chairman of the Board;
      2. MNRB’s Chairman of Audit Committee; and
      3. President & GCEO
      Official email:

      The role of recipients includes:

      i.To evaluate the issues / concerns disclosed and determine that there is a genuine concern to be investigated further; and
      ii.To decide on the next course of action at their discretion.
    4. Whistleblower
      i.Any person may disclose allegations of suspected misconduct or any breach or suspected breach of law or regulation that may adversely impact the Group.
      ii.Acts of misconduct may be disclosed via the e-mail sent to the dedicated e-mail addresses, verbally to designated person, or private meeting so as to assure a clear understanding of the issues raised. If desired, a form is made available for the Whistleblower to disclosure the misconduct.
      iii.In raising genuine concerns, Whistleblowers should note that:
      • it is best to raise early and identify or supply as much factual and verifiable facts and objective information pertaining to the issue / allegation;
      • to safeguard the abuse of this disclosure process, a malicious or knowingly false complaint will not be entertained and / or may lead to disciplinary / legal proceedings against the whistleblower; and
      • investigation / verification proceedings must not be discussed or disclosed to any other personnel in order to protect the integrity and confidentiality of the matter.
  6. Procedure
    1. Whistleblowing Procedures
      i.Whistleblower may disclose misconduct via the official emails. The disclosure shall include pertinent facts including:
      • The background, and chronology of events, with relevant dates of the issues concerned;
      • The reason why the Whistleblower is particularly concerned about the situation; and
      • Enclose any supporting or documentary evidence (if available).
      ii.If an allegation is raised verbally, the recipients of disclosures may put the verbal disclosure in writing, as soon as it is practical to do so. The information should be reviewed and confirmed by the person providing the information. This is to ensure that it properly reflects the concern that has been raised and it was accurately understood.
      iii.When dealing with a disclosure filed under the Whistleblowing Policy, the designated recipients of the disclosure must determine whether there is sufficient evidence to substantiate the disclosure and the corrective and preventive actions to be taken.
      iv.A register of all disclosures received shall be maintained at the President & GCEO’s Office.
      v.Any anonymous disclosure will not be entertained. Any employee or member of the public who wishes to report misconduct is required to disclose his or her identity for the Company to accord the necessary protection against him or her. However, the Company reserves its right to investigate into any anonymous disclosure.
    2. Investigation Procedures
      i.Designated Recipients may appoint an Investigating Officer from Group Internal Audit Department or any party deemed appropriate, to investigate the case and propose action to be undertaken. The Investigating Officer may arrange interviews with any persons deemed appropriate, depending on the nature of the allegation and to secure the discovery / disclosure of all relevant documents and information.
      ii.Where appropriate, the disclosure raised may be:
      • further investigated by the Group Human Capital Management Department, or dealt with through the disciplinary process;
      • referred to the relevant authority such as the Royal Malaysia Police, Malaysian AntiCorruption Commission, regulatory authorities, such as Bank Negara Malaysia, or any other regulatory authorities in other country, where applicable;
      • referred to the external auditor;
      • referred to an independent inquiry; or
      • referred to relevant external assistance other than those listed above.
      iii.The Group reserves the right not to inform the Whistleblower of the precise action plan and/or the outcome of the investigation as this may infringe a duty of confidentiality owned to someone else.
      iv.The concluded investigation report shall be tabled to the respective Board. The Board will evaluate and decide on the necessary action(s)
  7. Other Reporting Channel

    Individual may also report misconduct to relevant regulators or other law enforcement agencies such as Bank Negara Malaysia, Malaysian Anti-Corruption Commission or the Royal Malaysia Police.

  8. Awareness

    As far as reasonably practicable all directors and employees shall be given appropriate awareness of this Policy and such information is made accessible via the Corporate Portal. This shall include information on how to identify and disclose misconduct, communicate the protections afforded to Whistleblowers, and potential consequences of committing or being complicit to misconduct.

  9. Appendices
    i.Whistleblowing Process
    Whistleblowing Process
    ii.Whistleblower Disclosure Form