Whistleblowing Policy

    Objective
    ACSM personnel shall always bring themselves with a high standard of professionalism and integrities in carrying out our corporate and social activities.

    This Policy is intended to establish a robust, transparent and accountable communication channel for the employee and the public (whistle-blower) to voice their concerns in an effective, responsible and secured manner when they become aware of actual or potential wrongdoings, malpractice and/or irregularities that will cause ACSM to fall short of our social and corporate responsibilities.

    ACSM shall committed to create a secure, private and confidential channel for whistleblower to lodge a report and ACSM shall undertake swift, fair and effective investigation and corrective measure to maintain the integrity and ethical behaviour within ACSM and the trust of the public.

    Scope
    This Policy covers all reports made against any ACSM personnel who has committed an Improper Conduct (which is defined hereinafter) which are reported by Suppliers / Vendors / Tenants / Contractors of AEON and/or members of the public (whistle-blower).

    The Improper conducts shall include the following: -
    i. Failure to comply with legal or regulatory obligations
    ii. Corruption, bribery, fraud, theft or embezzlement
    iii. Money laundering
    iv. Insider trading
    v. Abuse of power by any director or officer of the Company
    vi. Conflict of interest
    vii. Misuse of Company’s fund or property
    viii. Misuse of Company’s information
    ix. Breach of policies and / or procedure
    x. Actions which can cause physical danger / harm to the company, customer, etc.

    All whistleblowing reports have to be made in good faith with reasonable belief that the information and allegation is true and not frivolously/maliciously and not for personal gain; otherwise, the necessary corrective action may be initiated against the whistle-blower.

    Designated Recipient
    All disclosures in relation to this policy shall be made to the following Designated Recipient:
    i. Senior Independent Director
    ii. Audit Committee Chairman
    iii. Chief Compliance Officer (CCO)

    The disclosures channel shall be as follows:
    i. eSID@aeoncredit.com.my

    Alternatively, the disclosures may be directed to Malaysian Anti-Corruption Commission via https://www.sprm.gov.my/

    Monitoring and Reviewing the Report
    • CCO shall maintain a Record Log for all disclosures made under this Policy. All documents obtained pertaining to the disclosures shall be considered “Confidential”.

    • On a quarterly basis, CCO shall updates the Board Risk Committee and the Board of Director on statistics pertaining to the disclosures such as number of disclosures received to date and nature of such disclosures, status of investigations, and other relevant updates.

    Protection
    • Upon making a disclosure in good faith, based on reasonable grounds, in accordance with the procedure pursuant to this Policy and clauses of the Whistleblower Protection Act 2010 (Section 7, 8, 9 and 10):
    i. The Whistle-blower shall be protected from reprisal within the Company as a direct consequence of his/her disclosure;
    ii. The Whistle-blower shall have immunity from civil and criminal action;
    iii. The Whistle-blower shall have protection from detrimental action; and
    iv. The Whistle-blower’s identity shall be protected

    • If the Whistle-blower, in good faith, reasonably believes they are being subjected to harassment, victimisation or reprisal as a direct consequence of having made a disclosure under this Policy, they may consult the Designated Recipient in confidence.

    • The Company does not permit retaliation of any kind against the Whistle-blower for complaints submitted hereunder that are made in good faith. Any such reprisal shall in itself be considered a serious breach of this Policy. A reprisal may result in disciplinary action, including a warning or letter of reprimand, demotion, loss of merit increase, loss of bonus, suspension without pay or termination of employment, as defined under the Code of Conduct, Disciplinary Policy and Procedures.

    Revocation of protection
    Under Section 11 (1) (a) to (f) of the Whistleblower Protection Act 2010, the Whistle-blower’s protection shall be revoked if a person is found to have:
    i. committed a wrongdoing;
    ii. made a disclosure not in accordance with the requirements of this Policy (for instance, dishonest, frivolous mischievous or malicious complaints);
    iii. made a disclosure to avoid dismissal or other disciplinary action by seeking protection under the Whistleblower Protection Act 2010;
    iv. violated the Whistleblower Protection Act 2010 in the course of making the disclosure or providing further information;
    v. made a disclosure specifically prohibited by written law, as prescribed under Section 6(1) of the Whistleblower Protection Act 2010;
    vi. made a disclosure of improper conduct which principally involves questioning the merits of the government policy, including the policy of a public body; or
    vii. participated or assisted in any process pursuant to the his Policy, otherwise than in good faith.

    Review of this Policy
    This policy shall be reviewed to reflect any changes in relevant laws and guidelines. Any proposed changes to this Policy shall be prepared by Legal and Compliance and tabled to the Board for approval. As a minimum, this Policy shall be reviewed on an annual basis.


    Whistleblowing Procedure

    Reporting
    ACSM personnel shall always bring themselves with a high standard of professionalism and integrities in carrying out corporate and social activities. Suppliers / Vendors / Tenants / Contractors of AEON and/or members of the public (whistle-blower) shall report any Improper Conduct committed by of any ACSM personnel. Either Human Resources (HR) – Industrial Relation (IR) or Chief Compliance Officer (CCO) shall investigate issue highlighted before reporting to respective committees. Issues and whistle-blower shall always be kept “Confidential”.
    • Whistle-blower shall lodge a report of suspected any Improper Conduct that committed by any staff in Aeon Credit
    • Whistle-blower shall indicate title of the email as : STRICTLY PRIVATE & CONFIDENTIAL
    • Whistle-blower shall include specific information such as below but not limited to:
    (a) Whistle-blower personal details (name, contact number)
    (b) Type of activity or conduct
    (c) Who is/are suspected as being involved
    (d) how it happened
    (e) when it occurred and
    (f) who was affected.
    • An auto reply shall be sent to the sender.
    • Recipients shall review report accordingly in order to conduct assessment and investigation.
    • Anonymous reports are not encouraged as any follow up to ascertain the facts or to obtain further information for investigation purposes would be very difficult.
    • Although the Company is not expected to address any anonymous allegations, the Company may, however, consider investigating an anonymous allegation after having considered the following:
    (a) the seriousness of the concern;
    (b) the credibility of the concern; and
    (c) the likelihood of confirming the concern from credible sources.