MADACorp Whistle Blowing Policy

POLICY STATEMENT

Syarikat Perniagaan Peladang (MADA) Sdn Bhd and Group of Companies (“MADACorp Group”) is committed to promote and maintaining high standards of transparency, accountability, ethics and integrity at the workplace in line with its Integrity, innovation, Teamwork, Excellence and Commitment (“INTEC”) values. An accountable and transparent workplace provides a mechanism for employees to voice genuine concerns in a responsible and appropriate manner.

OBJECTIVE

Consistent with this commitment, the policy aims to support good management practices and sound corporate governance practices. This Policy is formulated to help employees and third parties report possible improprieties at the earliest opportunity so that concerns can be raised without fear of reprisal or detrimental action.

SCOPE

This Policy applies to all employees and third parties who has become aware of or genuinely suspects on a reasonable belief that an employee of the Company has engaged, is engaged or is preparing to engage in any Improper Conduct.

For the purpose of this policy, the wrongful activities or wrongdoings refer to any potential violations or concerns relating to any laws, rules, regulations, acts, ethics, integrity and business conduct, including any violations or concerns relating to malpractice, illegal, immoral, embezzlement and fraudulent activities which will affect the business and image of MADACorp Group.

WHAT IS WHISTLE-BLOWING?

Whistleblowing provides an avenue and a structured mechanism for a person to raise or report concerns at an early stage about ongoing or suspected wrongful activities or wrongdoing within MADACorp Group and, to protect the value of integrity, transparency and accountability in where MADACorp conducts its business and affairs.

IMPROPER CONDUCT

Improper Conduct is any conduct which, if proved, constitutes a disciplinary action or a criminal offence. The following are generally accepted as improper and reportable conduct for whistleblowing:

  • Failure to comply with legal or regulatory obligations;
  • Criminal offence, unlawful acts, fraud, corruption, bribery and blackmail;
  • Criminal breach of trust;
  • Unofficial payoffs;
  • Collusion and money laundering;
  • Improperly discriminatory;
  • Misuse or abuse of MADACorp Group’s funds or assets or assets misappropriation;
  • Abuse of power by an officer of the Company;
  • Gross mismanagement within MADACorp Group;
  • Gross negligent;
  • Serious financial irregularity or financial fraudulent within MADACorp Group;
  • Breach of MADACorp Group’s Standard Operating Procedures;
  • Breach of MADACorp Group’s Financial Authority Limit;
  • Repeated ill treatment of a client/customer/supplier despite a complaint being made;
  • Activities, which otherwise amount to serious improper conduct, including MADACorp Group’s Code of Ethics;
  • An act or omission which creates a substantial and specific danger to the lives, health or safety of the employees or the public or the environment;
  • Unsafe work practices or substantial wasting of company resources;
  • Actions which endanger National and public interest;
  • Illegal or unlawful conduct or failure to comply with the provisions of the Government Laws and Regulations where the wrongdoer, knowingly, disregards or does not comply with such provisions;
  • Sexual harassment;
  • Knowingly directing or advising a person to commit any of the above wrongdoings; and
  • Any action which is intended to conceal any of the above.

RAISING A CONCERN

Anyone has the right to whistle-blow.

This Policy applies to all matters involving the Employees of MADACorp Group including, employees on contract terms, temporary or short-term employees and employees on secondment, Board members, Ex-employees, Financiers, Customers, Shareholders, Company performing services and supplying materials/products (here-in-after collectively referred as “service providers”) for MADACorp Group which includes contractors, suppliers, advisors, consultants, external auditors; and Members of the public.

No employees or Directors may use their position to prevent an individual to report any ongoing and suspected wrongful activities or wrongdoings.

The Whistleblowing Channels is a medium that allows all employees and members of the public to confidentially alert an organisation about suspicious misconduct and report any wrongful activities or wrongdoings. The particular Whistleblowing Channels are as follows:

A disclosure of Improper Conduct may be made orally or in writing by marking “Private and Confidential” (via a letter or electronic e-mail) to the following address:

To: MADACorp Audit and Risk Committee

Tingkat 11, Menara Peladang,

Jalan Teluk Wanjah,

05200 Alor Setar, Kedah.

Or;

Email to wb@madacorp.com.my;

When a disclosure is made orally, the person receiving the disclosure shall, as soon as it is practicable, reduce the same to writing. Any Improper Conduct that is discovered or genuinely suspected by the Whistleblower shall be reported immediately to the Head of Audit and Corporate Governance Department.

Alternatively, the Whistleblower may report directly to relevant government or regulatory authorities and enforcement agencies in Malaysia as prescribed by the Whistleblower Protection Act 2010 such as Malaysian Anti-Corruption Commission (MACC), Police, etc.

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

  • The whistleblower is encouraged to put their names to allegations, designation, current address and contact numbers to speed up the investigation process.
  • The whistleblower should inform the Audit and Risk Committee of all details of his or her concerns as reasonably possible, including other details deemed.
  • Provide further clarifications and information from time to time, for example, if an investigation is conducted.
  • In respect of the whistleblower, MADACorp Group will attempt to keep its discussions and actions confidential to the greatest extent possible.
  • However, there may be circumstances where the whistleblower may be needed as a witness

RESPONSIBILITY

Responsibility of Whistleblower:

  • Whistleblower makes the disclosure in good faith.
  • Whistleblower reasonably believes that the information and allegations are substantially true.
  • Whistleblower is not acting for personal gain. If the case involves the complainant’s personal interests, it must be informed at the outset.

Reporting under this policy, however, would not immunise or shield a whistleblowing against action following from his or her intentional misconduct. Where a whistleblower makes a report not in good faith or reasonably believed not to be true, the whistleblower will not be protected and will be subjected to Disciplinary Action by MADACorp Group in accordance with the Policy of Human Resources and Procedures Manual of MADACorp Group.

PROTECTION

The Whistleblower or persons connected to him/her shall be protected from any detrimental action as a direct consequence of the disclosure. Additionally, the Whistleblower’s identity and such other confidential information shall not be disclosed save with the Whistleblower’s consent or otherwise required by law. The protection conferred under this Policy is not affected notwithstanding that the disclosure of the improper conduct does not result in any disciplinary action on the person against whom the disclosure was made. Protection is in line with the Whistleblower Protection Act 2010.

NOTIFICATION

The Whistleblower shall be informed of the result of any investigation and/or any action taken by the Company in respect of the disclosure in accordance with the Policy.

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