- Purpose
The purpose of this MSI Whistleblowing Policy is to expect our employees to conduct themselves with a high standard of professionalism and ethics in the conduct of our business and operations.
As part of good corporate governance, the whistleblowing policy is established to set out avenues for legitimate concerns to be objectively investigated and addressed. Individuals will be able to raise concerns about illegal, unethical or questionable practices in confidence and without the risk of reprisal.
- Scope of Whistleblowing Policy
The Whistleblowing Policy applies to all MSI Board of Directors, management and staff.
- Whistleblowing
3.1 Whistleblowing is the voluntary disclosure of inappropriate, unethical or unlawful behaviour and practices by the management or employees. It includes how employees, customers and stakeholder are treated. The following are generally accepted as improper and reportable conduct for whistleblowing, but is not limited to:
- Any unlawful or illegal activities, whether criminal or breach in civil law;
- Breach of policies, procedures and/or Code of Ethics;
- Fraud, theft, embezzlement or dishonesty;
- Abuse of power by employer, management or Board of Directors;
- Corruption/bribery;
- Bullying and harassment;
- Actions which can cause physical danger/harm to another person and/or can give rise to risk of damage to properties/assets;
- Forgery or alteration of any documents belonging to the Company, customers, another Financial Institution, or agents of the Company;
- Poor or unethical sales practices, including mis-selling;
- Profiteering as a result of insider knowledge;
- Failure to manage responsibilities;
- Conflict of interest;
- Misuse of position or information; and
- Any other similar or related irregularities.
3.2 When the complaint is received, the whistleblower must be informed within three (3) working day that attention and action is being taken. Cases are consulted and finalised by the Risk committee within 90 days from the date the complaint is received.
3.3 Complaints that do not include the informant’s personal details are not accepted and are kept for record purposes only.
- Who should raise a concern?
Anyone has the right to whistle blow. This policy applies to all matters involving the MSI’s employees (including former employees and irrespective of nature of employment status), customers and any other stakeholders/persons providing services to MSI, including consultants, vendors, independent contractors, external agencies and/or any other party with a business relationship with MSI.
- How to make a disclosure?
Any disclosure can be made to any of the following dedicated reporting channels:
- Email directly to whistleblowing@malaysiasteelinstitute.com. The email is managed by MSI Integrity Officer
- Submission of whistleblowing disclosure form to MSI Integrity Officers. The form (Attachment 1) is available at MSI website (https://malaysiasteelinstitute.com/)
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 incidence;
- The identity of the wrongdoer;
- Particulars of witnesses (if any);
- Supporting evidence and/or documents (if any);
- Other details deemed to be useful to facilitate screening and action to be carried out.
Where possible, the whistleblower is encouraged to disclose his/her personal details to enable the relevant parties conducting the investigation to contact the whistleblower for further information:
- Name; and
- Contact details – email address and/or telephone number.
- Risk Committee
MSI Risk Committee is chaired by an independent body (member of MSI Board of Directors). This committee provides oversight to ensure that disclosures made via the whistleblowing channels are accorded with adequate attention, independence, investigation and remedial action, where necessary.
- How does the Risk Committee handle the information provided
After having examined the information disclosed, the Risk Committee will consult with the Board of Director and decide whether it warrants an investigation or may decide that other actions to be undertaken.
Depending on the outcome of the investigations, the Risk Committee shall recommend the appropriate action(s) to the Board of Director. Board of Director shall be briefed on the matter.
- Whistleblower Protection
8.1 MSI commits to ensure that all disclosed information, including the identity of the whistleblower shall be treated with strict confidentiality. All personnel, directly or indirectly working relative to a whistleblowing case, shall strictly protect the identity of the whistleblower and witnesses from unauthorised disclosure before, during and after an investigation.
8.2 MSI is also committed to protect the whistleblower from all acts of harassment, retaliation, victimisation and recrimination arising from making the disclosure in good faith.
8.3 Employees who whistleblow in good faith will also be protected by MSI from any repercussion.
8.4 There may be certain circumstances where the identity of the whistleblower may need to be revealed on needing to know basis (e.g. requirement to testify in court). If such a situation arises, the Risk Committee shall discuss and seek consent with the whistleblower first before proceeding with the case.
8.5 The protection will be removed, if it is found that the whistleblower was also involved in the improper conduct, or if the whistleblower is found to have made the disclosures in bad faith.
- 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.
- Whistleblower must whistle blow with strong evidences.
Whistleblowing Form
Please download here