Whistleblowing
IF YOU SEE SOMETHING, SAY SOMETHING
By doing the right thing, we are holding the wrong-doers accountable.
SEEN ANY OF THESE?
- Bribe
- Forgery
- Corruption
- Gratification
- Fraud
- Extortion
- Conflict of interest
- Embezzlement
- other unethical activities
TELL US:
Verbal (face-to-face) to the Designated Officer
Encik Fadzlan Dato’Abdul Samad
Dato’ Dzulkifli Mahmud
Write and mail to:
WHISTLEBLOWING DESIGNATED OFFICER
Export-Import Bank of Malaysia Berhad
P.O. Box 10176, Pejabat Pos Besar
50706 Kuala Lumpur
Write and email to:
This email address is being protected from spambots. You need JavaScript enabled to view it.
Whistleblowing Policy
Policy Statement
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
Objective of The Policy
The policy provides avenue for all employees of the Bank, Directors, 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.
Disclosure of Wrongdoings
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
Applicability of The Policy
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.
Confidentiality
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.
Underlying Shariah concept
In line with the concepts used for the Bank’s existing product offerings.
Protection to Whistleblower
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.
Anonymous Whistleblower
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 Company 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)
- What is Whistleblowing?
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. - What is the Whistleblower Policy (WBP)?
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. - Who is a "whistleblower"?
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. - Who can blow the whistle?
- Directors of the Bank;
- 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.
- Why did the Bank develop this policy?
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. - What kind of "unethical activities" can I blow the whistle on?
- 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 BNM/GP7 – Guidelines on the Code of Conduct for Directors, Officers and Employees in the Banking Industry
- What information should I provide when I make the disclosure?
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
- I am not certain whether the act or omission constitutes misconduct or criminal offence. Should I still make the disclosure?
Yes. The committee will determine whether the disclosure constitutes an improper conduct or criminal offence. - What should I do if I want to blow the whistle? How do I do it and to whom do I go?
You may blow the whistle verbally or in writing. Any channel used will only be accessed by the authorised Designated Officer only.- For verbal Disclosure (face-to-face),you will be interviewed by the Designated Officer (“DO”) and on behalf of the Whistleblower, the DO 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 :
- Whistleblowing Designated Officer
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 This email address is being protected from spambots. You need JavaScript enabled to view it.
- Fill up the e-Form and click submit, which will be directly sent to This email address is being protected from spambots. You need JavaScript enabled to view it.
- Whistleblowing Designated Officer
- Will my whistleblower report be held in confidence?
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 Officers (DOs) 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. - What if I don't want anyone to know I blew the whistle (Anonymous)?
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. - What information should I provide when I make my 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. - What if I don't feel comfortable making a report to the Designated Officers because I feel there are conflicts of interest?
If the potential allegation involves the Designated Officers who consist of Directors of the Board, you may file the report directly to the Chairman of the Board.
If the allegation is regarding the Chairman of the Board, you may report directly to the enforcement authority namely Malaysian Anti Corruption Corporation (MACC) through its various reporting channels, e.g. Online, hotline, e-mail, MACC mobile apps, walks-in, write-in, SMS and fax. Whistleblowers who report directly to MACC are protected under the MACC Act 2009, as well as the Whistleblower Protection Act 2010. - Is there a deadline for filing a whistleblower report?
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. - What happens after I file my whistleblower report?
A preliminary investigation will be conducted and you may be contacted for an interview. The preliminary investigation will determine if a full investigation should be undertaken and by whom. - Under what circumstances would my allegation might not be investigated?
The allegation might not be investigated if:- It concerns grievances instead of misconducts.
- Anonymous reporting without enough supporting evidence,
- How can I help with the investigation?
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. - Will I be informed of the outcome of my report?
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. - Can I discuss the matter with family, friends and colleagues?
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 DOs.
Whistleblowing Reporting Form