Whistleblower Protection Policy
Introduction
AmFunds Management Berhad strictly forbids any act of bribery and corruption regardless of its form as it has an adverse effect on the communities where such misconduct takes place. You should never offer, solicit, give or even accept any form of improper payment such as bribes or kickbacks. A bribe or a kickback is not just in the form of cash but it can be anything of value that is offered in exchange for business favours, information, and favourable treatment or similar.
The following are several examples of scenarios, warning signals and payment types that are prohibited (non-exhaustive):
- Any request for cash payment or for payment to be diverted to a third party or third country outside normal payment terms and processes
- Doing business with a potential customer in a country that has a history of corruption, particularly when the business sector or party has a reputation for corrupt practices
- Payments to influence the award of contracts
- Payments to obtain confidential information about the activities of competitors
All AmFunds Management Berhad employees must act ethically as we do not tolerate bribery and corruption. You are expected to report any suspicious activity regarding inappropriate payments immediately through the channels highlighted in the Code of Conduct.
Objectives
The Whistleblower Protection Policy aims to achieve the following objectives:
- Safeguard AmFunds Management Berhad’s reputation
- Protect Whistleblowers from detrimental actions
- Facilitate timely escalation of improper conduct in a professional manner
- Investigate and manage disclosed or reported improper conduct through established appropriate processes to ensure consistent and timely response
Disclosure Requirements
| Pre-requisite | Details |
|---|---|
Whistleblower's Identity | • Name (strongly encouraged even though Whistleblower may choose to remain anonymous) |
| Definition of Improper Conduct | Any conduct, deliberate act or failure to act which if proven, constitutes a serious matter (e.g. disciplinary or criminal offence), may adversely affect AmFunds Management Berhad’s performance and/or with the intention of obtaining unauthorised personal benefit. For example: • Dishonest, fraudulent, corruption, bribery or illegal practices • Manipulation of accounts • Unethical behavior • Abuse of power • Violation of laws and constitution • Conflict of interest |
| Disclosure Report | • Description of the alleged event or matter • Name(s) of the person(s) involved • Date and location of the event • Supporting/documentary evidence • Disclose using template enclosed e.g. Report of Concern • All information provided will be kept confidential |
| Disclosure Channels | • All correspondences to be addressed directly to the designated Board Ombudspersons via a sealed envelope marked “Strictly Private & Confidential” at Level 25, Bangunan AmBank Group, 55 Jalan Raja Chulan, 50200 Kuala Lumpur, Wilayah Persekutuan or the Whistleblower may email to the designated Board Ombudspersons at [email protected] • Alternatively the Whistleblower may write directly to the relevant regulatory authorities as prescribed by the Whistleblower Protection Act 2010 including but not limited to Bank Negara Malaysia (BNM), Securities Commission (SC) and Malaysian Anti-Corruption Commission (MACC). |