Whistleblowing Policy

Introduction

In line with the Company’s best practice on corporate governance, the Company has established a Whistleblowing Policy to address the following:


  • Provide a mechanism and a minimum standard to adhere in combating corruption and other improper conducts within the organisation
  • Encourage and facilitate disclosure of any improper conducts which may adversely affect to a material extent the financial position and/or reputation of the Company.
  • Protect the whistleblower from reprisal as a direct consequence of making a disclosure by safeguarding his/her identity and the concern with confidentiality

Types of Improper Conduct
  • Any fraud;
  • Sexual harassment;
  • An act of dishonesty, corrupt, abuse of power or authority for personal financial gain, any unauthorized or ulterior purpose;
  • Any material breach of the Legislation governing the business and operations of the Company, Company’s Code of Conduct, and internal Policies & Procedures;
  • Any malpractice or misdeed, unethical and unlawful activity with regards to privileged information, material non-public information, market manipulation, rogue trading, market rigging, forgery, misappropriation of funds and/or assets, and any other unprofessional conduct that is a violation of the Company’s Code of Conduct and Legislation; or
  • Any unethical, questionable or creation/provision of false or misleading information (including suppression of any material facts or information).

Protection of Whistleblower
  • The identity of the Whistleblower will be kept confidential by the Authorised Recipient only and remained anonymous until the case is concluded, unless so required under the provisions of the applicable laws and regulations or this Policy, and for the purpose of conducting a competent investigation and take any remedial action.
  • All information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action.
  • The amount of contact with the Whistleblower will be kept at a minimal and discussions will only be held for the purpose of obtaining clarity of the information provided.
  • Should the Whistleblower self disclose his or her own identity the Company will no longer be obligated to maintain such confidence.
  • The Whistleblower will be protected under Section 10(1) of the Whistleblowing Protection Act 2010 to the extent if the Whistleblower is a person related or associated with the Whistleblower.

Reporting

The Whistleblower may raise his/her concern in writing (via prescribed form) or through verbal communication to the relevant Authorised Recipient. An Authorised Recipient refers to a person that is officially appointed by the Board of Directors of i-VCAP with the primary responsibility to receive reports of allegations of improper conduct. The Authorised Recipient are appointed depending on the following categories:


Category Authorised Recipients
For reports / concerns against employees of any level Chief Executive Officer
For reports / concerns against the Chief Executive Officer, Investment Committee members or any directors (except Chairman of Board Audit & Risk Management Committee) Chairman of Board Audit & Risk Management Committee
For reports / concerns against the Chairman of Board Audit & Risk Management Committee Chairman of i-VCAP

The whistleblowing channels are as follows:
 

Whistleblowing e-Form
E-mail:
CEO: mahdzir@ivcap.com.my
Chairman of BARMC: nasir.ali@ivcap.com.my
Chairman of i-VCAP: rosli.abdullah@ivcap.com.my
Telephone : (603) 2711 9118
Address:
i-VCAP Management Sdn. Bhd.
Level 9, Block B, HP Towers
No. 12, Jalan Gelenggang
Bukit Damansara
50490 Kuala Lumpur
Attention: Authorised Recipient (please state designation of AR)