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Whistle Blowing Policy and Procedures

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Whistle Blowing Policy and Procedures

1. Objective
The objective Whistle-Blowing Policy and Procedures (the “Policy”) is to address the avenues available for all employees of Seremban Engineering Berhad (“SEB”) and its subsidiaries (“Group”) and all employees, ex-employees, shareholders, vendors, customers (collectively known as “stakeholder”) as well as members of public to raise genuine concerns about any wrongful activities in the conduct of the Groups’s business without fear of reprisal should they act in good faith when reporting such concerns.
2. Applicability
2.1 Scope
The policy and procedure is applicable to all companies within the SEB Group.
2.2 Subject of concerns
The types of improper conduct that may be raised under this Policy are concerns that could have an adverse impact on the operations and performance of the Group. Such concerns include, without limitation:
a) Irregularities of a general and/or operational nature, such as serious endangerments concerning the vital interests of the Group or the life or health or individuals, environmental crime, major deficiencies as regards security in the workplace, serious forms of discrimination or harassment, breach of standard operating procedures, misconduct; or
b) Accounting or auditing matters or irregularities of a financial nature, legal and/or ethical nature, such as:

i. Fraud (e.g. financial fraud, document fraud or embezzlement);
ii. Serious deficiencies or deliberate error (in, e.g. financial reports or internal accounting controls);
iii. Bribery or corruption
c) Any action which is intended to conceal any of the above.
3 Principles
a) Whistle-Blowing is a specific means by which a worker or stakeholder can report or disclose through established channels, concerns about unethical behavior, malpractices, illegal acts or failure to comply with regulatory requirements that is taking place / has taken place / may take place in the future.
b) Only genuine concerns should be reported under Whistle-Blowing procedures. The report should be made in good faith with a reasonable belief that the information and any allegation in it are substantially true, and the report is not made for personnel gain. Malicious and false allegations will be viewed seriously and treated as gross misconduct and if proven true, may lead to dismissal.
c) SEB views any harassments or retaliations in any form or manner against genuine whistle blower seriously and will treat such action as gross misconduct, which if proven, may lead to dismissal.
d) No employees may use their position to prevent an individual to report any on-going and suspected wrongful activities.
4 Procedures
4.1 Endorsement
a) The Board shall exercise oversight function over the administration of the Policy
b) The administration of the Policy and guidelines is to be carried out by the Chief Executive Officer (“CEO”) of SEB.
c) For internal circulation within SEB Group, the Policy is made available via circulations of memo/emails. It is deemed to be considered that all employees are aware, has read and understand the content of this Policy.
d) Training and awareness on whistle-blowing key processes and updates will be communicated via continuous awareness programme.
4.2 Channels of Reporting
a) Any concern should be raised with the immediate superior. If for any reason, it is believed that this is not possible or appropriate, then the concern should be reported to The CEO. Channels of reporting to CEO are:
Telephone : 06-6775898
Mail : Lot 1A-1C, Lorong Bunga Tanjung 1/3 Senawang industrial Park, 70400 Seremban Negeri Sembilan Darul Khusus
Attention : CEO
Email : ceo@seb.net.my
b) In cases where reporting to management is a concern, then the report should be made to the Chairman of Audit Committee. Channels of reporting to the Chairman of Audit Committee are:
Telephone : 06-677 5898
Mail : Lot 1A-1C, Lorong Bunga Tanjung 1/3 Senawang industrial Park, 70400 Seremban Negeri Sembilan Darul Khusus
Attention : Chairman of Audit Committee
Dedicated Email : ac@seb.net.my
4.3 Confidentiality
a) Although a report may be lodged anonymously, we strongly urge the whistleblower to provide details when lodging a report including below information:

i. Name of individual raising the concern
ii. Contact particulars of the individual raising the concern
iii. Details of the concern, including nature, parties involved, date, time, location of the incident, etc.
iv. Name of possible witness(es) to the incident (if any); and
v. Supporting evidence in any form, if any.
b) Should be whistle blower identifies him/herself, the identity of the whistle blower will not be disclosed to preserve his/her anonymity for as long as it is permitted by law or when the whistle blower decides otherwise.
c) The whistle-blower shall be protected against reprisals or retaliations from the Group’s Management. The Group shall take reasonable steps to ensure he is granted immunity from any disciplinary action by the whistle-blower’s superior or any other person exercising power over the whistle-blower’s employment.
4.4 Investigation and Outcome
a) All reports will be investigated promptly by the person receiving the report. If required, he can obtain assistance from other resources within the Group (e.g. Group Finance Department and Group Human resources Department, etc.) The progress of investigation will be reported to the Audit Committee no later than at the next scheduled meeting.
b) All whistle blower reports will be treated as confidential irrespective of whether the whistle blower identifies him/herself when reporting.
c) All whistle blower reports made in good faith will be taken seriously and investigated irrespective of whether the whistle blower identifies him/herself.
d) Upon completion of investigation, appropriate course of action will be recommended to the Audit Committee for their deliberation. Decision taken by the Audit Committee will be implemented immediately.
e) Where possible, steps will also be implemented to prevent similar situation arising.
4.5 Appeal
a) If for any reason, the person making the report is not satisfied with the way his/her report had been dealt with, he/she can escalate his/her report to the Chairman of Audit Committee personally. Channels of reporting to the Chairman of Audit Committee are:
Telephone : 06-677 5898
Mail : Lot 1A-1C, Lorong Bunga Tanjung 1/3 Senawang industrial Park, 70400 Seremban Negeri Sembilan Darul Khusus
Attention : Chairman of Audit Committee
Dedicated Email : ac@seb.net.my
b) Chairman of Audit Committee will deliberate the report with his/her Committee members and decide on the appropriate course of action.
5 Review and Amendment
a) The Board will monitor compliance with the Policy regularly and review the Policy at least once every three (3) years to ensure it continues to remain relevant and appropriate.
b) This Policy is made available to public via the Company’s corporate website.

 

Updated as at 24 October 2024

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