-
Whistleblowing
If you see something, say it.
Seen any of these?
- Bribe
- Forgery
- Corruption
- Gratification
- Fraud
- Extortion
- Conflict of interest
- Embezzlement
- Criminal offences
- Other unethical activities
If the alleged wrongdoer is the following:
| Alleged Wrongdoer | Designated Person | Whistleblowing Channels |
|---|---|---|
|
Designated Whistleblowing Officer (DWO) |
i) Verbal The DWOs, on behalf of Whistleblower, must commit to writing the Disclosure and the written Disclosure must be confirmed by the Whistleblower. ii) Letter The Whistleblower can raise their concerns or complaints by completing the Whistleblowing Reporting Form as attached in “Appendix B” or sealed letter addressed to: Designated Whistleblowing Officer Export Import Bank of Malaysia Berhad Peti Surat 10176 Pejabat Pos Besar KL 50706 WPKL iii) E-mail to: whistleblower@exim.com.my (An auto acknowledgement email will be sent to the sender.) |
| Alleged Wrongdoer | Designated Person | Whistleblowing Channels |
|---|---|---|
|
Designated Whistleblowing Director (DWD) |
i) Verbal The DWD, on behalf of Whistleblower, must commit to writing the Disclosure and the written Disclosure must be confirmed by the Whistleblower. ii) Letter The Whistleblower can raise their concerns or complaints by completing the Whistleblowing Reporting Form or sealed letter addressed to: Designated Whistleblowing Director Export Import Bank of Malaysia Berhad Peti Surat 10176 Pejabat Pos Besar KL 50706 WPKL |
If the alleged wrongdoer is the following:
| Chairman, Directors, Shariah Committee, PCEO, Employees | Designated Whistleblowing Officer (DWO) IID Staff | |
|---|---|---|
| Channel to : |
Designated Whistleblowing Officer, Head of Integrity & Investigation Department |
Designated Whistleblowing Director (DWD), Chairman of Board Audit Committee (BAC) |
| Whistleblowing Channels : |
Verbal The DWO on behalf of the Whistleblower shall commit to writing the Disclosure and the written Disclosure shall be confirmed by the Whistleblower. Letter Designated Whistleblowing Officer, Export-Import Bank of Malaysia Berhad, P.O. Box 10176, Pejabat Pos Besar, 50706 Kuala Lumpur. Email to whistleblower@exim.com.my |
Verbal The DWD on behalf of the Whistleblower shall commit to writing the Disclosure and the written Disclosure shall be confirmed by the Whistleblower. Letter Designated Whistleblowing Director, Export-Import Bank of Malaysia Berhad, P.O. Box 10176, Pejabat Pos Besar, 50706 Kuala Lumpur. |
Whistleblowing Policy
The Whistleblowing Policy is intended to uphold and reinforce the Bank’s Core Values, Code of Ethics, and Governance principles. At EXIM Bank, trust and integrity are held in the highest regard as essential attributes of all employees. This policy aims to foster a safe and transparent environment by encouraging employees and relevant stakeholders to report any concerns or misconduct within the Bank, enabling timely internal resolution prior seeking resolution outside
The policy provides avenue for all employees of the Bank, Directors, Shariah Committee, Shareholders, Customers, Consultants, Vendors, Contractors, agencies or any parties with a business relationship with the Bank to disclose any unethical conduct or malpractice in accordance with the procedures as provided under this policy and to provide protection for employees and members of the related parties who report such allegation.
Subject to the requirement of applicable local jurisdiction, this policy applies to all employees of EXIM Bank and external parties which have business dealings with EXIM Bank. This policy also applies to members of the public, where relevant.
The Bank shall take all necessary measures to ensure that the identity and personal information of the Whistleblower shall be protected at all time and kept confidential, to the extent reasonably practicable unless otherwise required by the law, or for the purpose of any proceedings by the Bank. In such a case, the Bank shall notify the Whistleblower before revealing their identity.
In line with the concepts used for the Bank’s existing product offerings.
A whistleblower will be accorded with protection of confidentiality of identity, to the extent reasonably practicable. Such protection is accorded even if the investigation later reveals that the whistleblower is mistaken as to the facts and the rules and procedures involved.
Yes, you can submit a disclosure anonymously. However, The DWO, DWD and Whistleblowing Committee reserves the discretion whether to proceed with the investigation or otherwise if the provided details of concern and wrongdoing are not supported with sufficient information and evidence.
EXIM Bank reserves the right to amend this policy from time to time.
Whistleblowing Policy
The Whistleblowing Policy is intended to directly support the organisation’s Core Values, Code of Ethics and Governance requirement. EXIM Bank places high value on the level of trust and integrity expected of its employees. It is also intended to encourage and enable employees and others to raise concerns within the Bank prior to seeking resolution outside
The policy provides avenue for all employees of the Bank, Directors, Shariah Committee, Shareholders, Customers, Consultants, Vendors, Contractors, agencies or any parties with a business relationship with the Bank to disclose any unethical conduct or malpractice in accordance with the procedures as provided under this policy and to provide protection for employees and members of the related parties who report such allegation.
A Disclosure of an unethical conduct and malpractice that may cause potential risk to the Bank shall include but not limited to the following issues:
- Bribery;
- Corruption;
- Forgery of Documents;
- Embezzlement;
- Gratification;
- Conflict of Interest;
- Fraud;
- Extortion
Subject to the requirement of applicable local jurisdiction, this policy applies to all employees of EXIM Bank and external parties which have business dealings with EXIM Bank. This policy also applies to members of the public, where relevant.
The Bank shall take all necessary measures to ensure that the identity and personal information of the Whistleblower shall be protected at all time and kept confidential, to the extent reasonably practicable unless otherwise required by the law, or for the purpose of any proceedings by the Bank. In such a case, the Bank shall notify the Whistleblower before revealing their identity.
In line with the concepts used for the Bank’s existing product offerings.
A whistleblower will be accorded with protection of confidentiality of identity, to the extent reasonably practicable. Such protection is accorded even if the investigation later reveals that the whistleblower is mistaken as to the facts and the rules and procedures involved.
Any anonymous disclosure will be entertained provided that the information / evidences received are sufficient and not frivolous. No protection will be given to anonymous whistleblower. However, the Bank reserves its right to investigate into any anonymous disclosure.
EXIM Bank reserves the right to amend this policy from time to time.
Whistleblowing Frequently Asked Questions (FAQ)
Whistleblowing is the reporting of an individual or organisational’s malpractice by any person suspected to be doing improper conduct within the Group or organisation, based on his or her reasonable belief.
Policy on Whistleblowing (PWB) enables the Bank staff, external related parties (i.e vendor, customer, consultants, stakeholder etc.) to raise concerns regarding any unethical conduct or malpractice at the earliest opportunity without being subject to victimisation, harassment or discriminatory treatment, and to have such concerns properly investigated.
A whistleblower is a person who raises concerns about wrongdoings in their workplace. Whistleblower is deemed to be protected under the Policy. The identity of the Whistleblower will be kept confidential, as long as it does not hinder or frustrate any investigation.
- Board of Directors of the Bank
- Shariah Committee
- Staff of EXIM Bank
- External parties that perform services for the Bank such as the agents, lawyers, contractors, consultants, suppliers, customers of the Bank, etc.
- Members of the public
The Bank places high value on the level of trust and integrity expected of its employees. This policy will directly support the Bank’s Core Values, Code of Ethics and Governance requirement.
- Corruption, bribery, graft, fraud, embezzlement or dishonesty
- Criminal offences, conflict of interest
- Abuse of position and misuse of the Bank’s fund and assets
- Intentional misrepresentations directly or indirectly affecting financial statements
- Breach of any legal obligations
- A serious breach of fundamental internal control, including policies and procedures
- Action that could cause physical danger to another person
- Action that could cause damage to properties/assets and environment
- Profiteering as a result of insider knowledge
- Forgery or alteration of any documents belonging to the Bank, customers, another financial institution, or agent of the Bank
- Revealing the Bank’s confidential or material information without proper authorisation
- Breach of any Guidelines related to the Code of Conduct issued by BNM for Directors, Officers and Employees in the Banking Industry
In order to carry out an investigation, details and information on the concern made by the Whistleblower should be disclosed. The Whistleblower is required to disclose his/her personal details (which will be kept confidential).
- Name
- Contact information – Mobile numbers, email address
- Nature of improper conduct
- The date and location of the incidence
- The identity of the alleged wrongdoer
- Particulars of witnesses, if any
- Particulars or production of documentary evidence, if any
- Any monetary values involved; if any
- Other details deemed to be useful to facilitate screening and action to be carried out
Yes. The Designated Whistleblowing Officer or Designated Whistleblowing Director will determine whether the disclosure constitutes an improper conduct or criminal offence.
We are committed to keeping your identity confidential, within the bounds of the law and the investigation process. Only the Designated Whistleblowing Officer (DWO) or Designated Whistleblowing Director (DWD) will have access to your identity for the purpose of investigating your report. Please be aware that legal requirements might necessitate the disclosure of your identity in certain situations. Additionally, if legal action is pursued, your testimony may be required. It’s also important to note that if you share your disclosure with others, we can no longer guarantee its confidentiality.
Yes, you can submit a disclosure anonymously. While anonymity is respected, it’s important to understand that it might affect your eligibility for whistleblower protection.
Please provide the factual details of your concern, including what happened, who was involved, and when it took place. To ensure an accurate investigation, it’s important to avoid speculation. Be prepared to answer any necessary follow-up questions from the investigator.
No, but it is important to file a report as soon as you have enough evidence to make a good faith report. If you delay, evidence becomes stale, hampering the investigation, and then the Bank may not be able to resolve the problem.
A preliminary investigation will be initiated, and you may be contacted by either Designated Whistleblowing Officer (DWO) or Designated Whistleblowing Director (DWD) for a confidential interview. This investigation will assess whether a full investigation is warranted and determine the appropriate parties to conduct it
- If it pertains to grievances rather than misconduct.
- If it is an anonymous report without sufficient supporting evidence.
However, if an investigation is not pursued, this does not imply that the concern will be dismissed. The Bank may still review the allegation and take appropriate action.
You can assist the investigation by providing all relevant facts and evidence. Avoid collecting information you are not authorized to access or conducting your own investigation. Be prepared to cooperate with investigators and share all information you have regarding the allegations.
You generally have the right to be informed of the outcome of your disclosure and the findings of any investigation, although there might be overriding legal or public interest reasons not to do so. However, any action taken against an employee, as a consequence of the findings of the investigation, may be personal and confidential, in which case, it cannot be disclosed.
No. You cannot disclose any information with anyone other than the Designated Whistleblowing Officer (DWO) or Designated Whistleblowing Director (DWD). Disclosing information to others could unintentionally hinder the investigation process and may impact our ability to guarantee confidentiality, particularly if your identity becomes known.
You may refer the disclosure to:
- BNM at Bank Negara Malaysia, Jalan Dato’ Onn, P.O Box 10922, 50929 Kuala Lumpur. Or via https://bnmlink.bnm.gov.my/
- PDRM at Polis Diraja Malaysia Headquarters, Bukit Aman, 50560 Kuala Lumpur. Or via email to rmp@rmp.gov.my
- MACC at MACC Headquarters, No. 2, Lebuh Wawasan, Presint 7, 62250 Putrajaya. Or via email to info@sprm.gov.my
EXIM Bank reserves the right to amend this policy from time to time.
Whistleblowing Frequently Asked Questions (FAQ)
Whistleblowing is the reporting of an individual or organisational’s malpractice by any person suspected to be doing improper conduct within the Group or organisation, based on his or her reasonable belief.
WBP enables the Bank staff, external related parties (i.e vendor, customer, consultants, stakeholder etc.) to raise concerns regarding any unethical conduct or malpractice at the earliest opportunity without being subject to victimisation, harassment or discriminatory treatment, and to have such concerns properly investigated.
A whistleblower is a person who raises concerns about wrongdoings in their workplace. Whistleblower is deemed to be protected under the Policy. The identity of the Whistleblower will be kept confidential, as long as it does not hinder or frustrate any investigation.
- Directors of the Bank;
- Shariah Committee
- Employees of the Bank – permanent (including staff under probation or seconded to a third party), contract and temporary staff;
- Third parties performing services for the Bank – agents, lawyers, contractors, consultants, suppliers, customer of the Bank, etc, and
- Members of the public.
The Bank places high value on the level of trust and integrity expected of its employees. This policy will directly support the Bank’s Core Values, Code of Ethics and Governance requirement.
- Corruption, bribery, graft, fraud, embezzlement or dishonesty
- Criminal offences, conflict of interest
- Abuse of position and misuse of the Bank’s fund and assets
- Intentional misrepresentations directly or indirectly affecting financial statements
- Breach of any legal obligations
- A serious breach of fundamental internal control, including policies and procedures
- Action that could cause physical danger to another person
- Action that could cause damage to properties/assets and environment
- Profiteering as a result of insider knowledge
- Forgery or alteration of any documents belonging to the Bank, customers, another financial institution, or agent of the Bank
- Revealing the Bank’s confidential or material information without proper authorisation
- Breach of any Guidelines related to the Code of Conduct issued by BNM for Directors, Officers and Employees in the Banking Industry
In order to carry out an investigation, details and information on the concern made by the Whistleblower should be disclosed. The Whistleblower is required to disclose his/her personal details (which will be kept confidential).
- Name
- Contact telephone numbers – mobile or office
- Nature of improper conduct
- The date and location of the incidence
- The identity of the alleged wrongdoer
- Particulars of witnesses, if any
- Particulars or production of documentary evidence, if any
- Any monetary values involved; if any
- Other details deemed to be useful to facilitate screening and action to be carried out
Yes. The Designated Whistleblowing Officer will determine whether the disclosure constitutes an improper conduct or criminal offence.
You may blow the whistle verbally or in writing. Any channel used will only be accessed by the authorised Designated Whistleblowing Officer (DWO) and Designated Whistleblowing Director (DWD) only.
- For verbal Disclosure (face-to-face), you will be interviewed by the DWO/DWD and on behalf of the Whistleblower, the DWO and DWD shall reduce to writing the Disclosure and the written Disclosure shall be confirmed and signed by the Whistleblower.
- For a written Disclosure, you may raise your concerns/complaints by writing a letter (with minimum information as per question no. 7) and attach the supporting documents and mail to :
- Designated Whistleblowing Officer / Designated Whistleblowing Director
Export-Import Bank of Malaysia Berhad
P.O Box 10176
Pejabat Pos Besar
50706 Kuala Lumpur
Or - Write (with minimum information as per question no. 7) and attach the supporting documents through email to whistleblower@exim.com.my
- Fill up the e-Form and click submit, which will be directly sent to whistleblower@exim.com.my
- Designated Whistleblowing Officer / Designated Whistleblowing Director
Confidentiality will be maintained to the extent possible within the limitations of law and the legitimate needs of the investigation. Your identity will, of course, be known to Designated Whistleblowing Officer (DWO) & Designated Whistleblowing Director (DWD) with a legitimate need to know in order to carry out an investigation. Release of your identity may be required pursuant to circumstances where the Bank is required by law to release information. In addition, you should also be aware that your public testimony might be needed to prove the case against the accused. If you self-disclose your identity, the Bank will no longer be obligated to maintain such confidence.
Anonymous disclosure is acceptable provided that the information/ evidences received are sufficient and not frivolous. The disadvantage of being Anonymous Whistleblower is that he/she would not be protected and will not be able to know the status of the Disclosure.
You should state the facts with as much specific information as possible so that your allegations can be investigated, such as what occurred, who was involved, and dates of occurrence. You should not speculate or draw conclusions, and should be prepared to be questioned by the investigator.
No, but it is important to file a report as soon as you have enough evidence to make a good faith report. If you delay, evidence becomes stale, hampering the investigation, and then the Bank may not be able to resolve the problem.
A preliminary investigation will be conducted and you may be contacted for an interview that will be performed discretely. The preliminary investigation will determine if a full investigation should be undertaken and by whom.
The allegation might not be investigated if:
- It concerns grievances instead of misconducts.
- Anonymous reporting without enough supporting evidence,
However, if the investigation is not carried out, it doesn’t mean that the complaint won’t be entertained. The Bank might have an option to review the allegation.
You can provide as much factual information and evidence as possible, in order to allow the investigation to proceed. However, don’t obtain any evidence for which you do not have a right of access and don’t do your own investigation. You should be prepared to be interviewed by the investigators and provide all the information you know about the allegations.
You generally have the right to be informed of the outcome of your disclosure and the findings of any investigation, although there might be overriding legal or public interest reasons not to do so. However, any action taken against an employee, as a consequence of the findings of the investigation, may be personal and confidential, in which case, it cannot be disclosed.
If you self-disclose your identity, the Bank no longer will be obligated to maintain your confidentiality. To protect your confidentiality and that of the investigation, it is advisable not to discuss the matter with anybody except the DWO.
You may refer the disclosure to:
- BNM at Bank Negara Malaysia, Jalan Dato’ Onn, P.O Box 10922, 50929 Kuala Lumpur. Or via email to bnmtelelink@bnm.gov.my
- PDRM at Polis Diraja Malaysia Headquarters, Bukit Aman, 50560 Kuala Lumpur. Or via email to mcc@rmp.gov.my
- MACC at MACC Headquarters, No. 2, Lebuh Wawasan, Presint 7, 62250 Putrajaya. Or via email to info@sprm.gov.my
EXIM Bank reserves the right to amend this policy from time to time.
