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Whistleblower Policy

WHISTLEBLOWER POLICY

 

 

  1. SCOPE AND PURPOSE

At Abletech Solutions Sdn Bhd and its subsidiaries (“SUBPLACE”, “the Group”), we take pride in our reputation and our commitment in prioritising the values of transparency, integrity, impartiality, and accountability in the conduct of its business and affairs. Every director, employee, vendor, contractor, consultant, agent, representative and other third parties performing work or services for or on behalf of the Group as well as all customers and other third parties receiving work or services from the Group plays an important part in maintaining this reputation and continuing to uphold the Group’s success.

In line with this commitment, we have put in place this Whistleblower Policy (hereinafter referred to as the “Policy”) and procedures to provide an avenue for our directors, employees, third parties (such as vendors, contractors, consultants, agents and business partners of Group) and persons acting on the Group’s behalf to disclose any improper conduct that may be illegal, unethical, corrupt, or otherwise cause damage to the Group’s reputation.

2. WHAT IS IMPROPER CONDUCT?

  1. Conduct by or any of the Group’s directors, employees, third parties (such as vendors, contractors, consultants, agents, and business partners of the Group) and persons acting on the Group’s behalf will be considered fraudulent, unethical, illegal, corrupt, or conflicting with the Group’s internal policies.

 

  1. Examples of improper conduct include but are not limited to:

 

  1. bribery and corrupt conduct;

  2. fraud, theft, embezzlement or dishonest conduct;

  3. breaches of policies, procedures and applicable laws and regulations in Malaysia;

  4. forgery or alteration of any documents belonging to the Group, customers, another Financial Institution, or agents of the Group;

  5. any form of harassment;

  6. misuse of position or information;.

  7. actions which can cause physical danger or harm to another person and/or can give rise to the risk of damage to properties or assets;

  8. conduct which may cause financial loss to the Group or bring it to severe public disrepute or ridicule or is otherwise detrimental to the Group’s interests;

  9. conduct that breaches any obligations under the Group’s code of conduct or any of the policies and procedures;

  10. unethical sales practices;

  11. conflict of interest; or

  12. misuse of position or information which may result in profiteering.

 

  1. This Policy excludes grievances, complaints, or concerns about:

  1. matters which are trivial or frivolous or malicious or vexatious in nature or motivated by personal agenda or ill will;

  2. matters pending or determined through the Group’s disciplinary proceedings; and

  3. matters pending or determined through any tribunal or authority or court, arbitration, or other similar proceedings.

 

3. REPORTING IMPROPER CONDUCT 

  1. Everyone has a right to whistleblow any known or suspected incidences of improper conduct of the Group or any of its directors, employees, third parties and person acting on the Group’s behalf.

  2. Reporting concerns can help SUBPLACE improve processes and solve problems quickly. Such an individual is referred to as a “Whistleblower”.

 

4. HOW TO MAKE A REPORT

  1. We take whistleblowing seriously and your concern matters to us. We would like to hear from you if any of your disclosure is related to improper conduct or practices occurring within or related to the Group. Any disclosure can be made to any of the following dedicated reporting channels:

 

  1. Complete the Whistleblowing Form and then send it to www.subplace.com or complete the whistleblowing form online through the SUBPLACE official website.

 

  1. To facilitate an investigation into the alleged wrongdoing, where possible and applicable, the following information should be included when making a disclosure:

  • brief description of the misconduct;

  • the date, time and location of the incident;

  • the identity of the wrongdoer;

  • your relationship with the wrongdoer;

  • particulars of witnesses (if any);

  • supporting evidence and/or documents; and/or

  • other useful details to facilitate screening and action to be carried out.

 

  1. Where possible, the Whistleblower is encouraged to disclose his/her personal details to enable the relevant parties conducting the investigations to contact the Whistleblower for further information:

 

  1. name; and

  2. contact details (email address and/or telephone number).

The report will be made directly to the Whistleblowing Committee.

 

5. HOW DOES SUBPLACE HANDLE INFORMATION PROVIDED BY WHISTLEBLOWER?

  1. SUBPLACE are committed to ensure that all disclosed information, including the identity of the Whistleblower shall be treated with strict confidentiality. The investigation will be carried out by the appropriate party. During the investigation, the investigator may reach out to the Whistleblower for additional information and/or documents to assist in the investigation.

  2. After reviewing the disclosure of the complaint of improper conduct, the Whistleblowing Committee will consult the designated Director (if the designated Director is not involved) to decide whether it warrants the disclosure for an investigation or may decide that further action is needed.

  3. To avoid jeopardising any investigation, the Whistleblower must use all reasonable efforts to keep the Confidential Information confidential, including the fact that a report has been filed, the nature of the Improper Conduct, and the identity of the person(s) who are allegedly responsible for the Improper Conduct.

  4. In the event the Whistleblower is not able to substantiate its allegations with reliable evidence, we will not be able to act on the report. Once the investigation has been completed, the findings of the investigation will be shared to the Whistleblower (except where the Whistleblower is not contactable).

  5. Appropriate corrective or disciplinary action, up to and including termination, will be taken where a finding of improper conduct is made.

  6. The Legal and Compliance department and/or Whistleblowing Committee that receives the report will conduct a preliminary assessment of the whistleblower case received. The Group reserves the right to drop the whistleblower case received due to insufficient evidence or other factors.

  7. Upon receive further instruction from the Top Management (provided that the Top Management is not among the subject matter of the report / complaint received), the Whistleblower committee will update the Whistleblower on the outcome and/or result of the investigation and action taken by the Management (if the Whistleblower disclose their personal details to be contacted by the Committee).The feedback letter to the Whistleblower shall be send via a written formal letter and/or via e-mail (whichever applicable to the Whistleblower). 

  8. The investigation process which started from receiving a report up till to the action taken by the Management against the issue raised by the Whistleblower; shall be completed within 14 to 21 working days. 

 

6. PROTECTION OF WHISTLEBLOWERS

  1. SUBPLACE are committed to ensure that a Whistleblower is not disadvantaged in any way for raising genuine concerns about known or suspected improper conduct.

 

  1. A Whistleblower will be protected from harassment, retaliation, victimization, and recrimination, where they make a report in good faith and where it can be demonstrated that there are reasonable grounds for the belief that improper conduct has occurred.

7. RECORD KEEPING / DOCUMENTED REPORTS

(a) All information, documents, records and reports relating to the investigation of an
      Improper Conduct shall be kept secure to ensure its confidentiality.

(b) Such information, documents, records, reports and any other related to a   whistleblowing matter shall be kept accordingly and shall only be assessed by the Legal and Compliance department and/or whistleblowing committee as and when necessary.

8. WITHDRAWAL OF REPORT

The Whistleblower who wishes to withdraw his/her report is required to write to whistleblowing@subplace.com together with supporting reason(s) for the withdrawal. Notwithstanding such withdrawal, SUBPLACE reserves the right to proceed with an investigation on the matters arising from the report.