“EURO’ means EURO Holdings Berhad [200401008055 (646559-T)], its subsidiaries, affiliates, associated entities and any of our offices (together or individually).
EURO is committed to a high standard of integrity, openness and accountability in the conduct of the businesses and operations in an ethical, responsible and transparent manner. In line with this commitment, all EURO’s employees and members of the public are provided with an avenue to raise genuine concerns and disclose any improper conduct at the earliest opportunity, and in an appropriate manner.
OBJECTIVE OF POLICY
This policy is designed to facilitate disclosure of any alleged improper conduct in:
- support of EURO’s values;
- ensuring protection for EURO’s employees and members of the public, who report such concerns without fear; and
- a transparent and confidential process.
SCOPE OF POLICY
This policy covers the following improper misconduct or criminal offences:
- Unlawful act, fraud, corruption, bribery or blackmail
- Abuse of Power
- Conflict of Interest
- Theft or embezzlement
- Misuse of EURO’s properties, monies and/or facilities
- Misuse of confidential information
- Non Compliance with EURO’s policies and procedures
- Failure to comply with legal or regulatory obligation
- Miscarriage of justice
- Endangerment of an individual’s health and safety
- Concealment of any of the above
The above list is not exhaustive and includes any act of omissions, which if proven, will constitute an act of misconduct or any criminal offence under relevant legislations in force.
The principles underpinning the policy are as follows:
- All concerns raised will be treated fairly and properly;
- EURO will not tolerate harassment or victimization of anyone raising a genuine concern;
- Any individual making a disclosure will retain anonymity unless the individual agrees otherwise;
- EURO will ensure that any individual raising a concern is aware of who is handling the matter; and
- EURO will ensure no one will be at risk of suffering any form of reprisal as a result of raising a concern even if the individual is mistaken. EURO, however, does not extend this assurance to someone who maliciously raises a matter that is not true.
If any EURO’s employee believes reasonably and in good faith that improper conduct exists in the work place, the employee should report this immediately to the immediate superior. Any EURO’s employee who has concern about speaking to another EURO’s employee, as well as any members of the public, can report and/or speak in confidence to:
- Group Managing Director - Dato’ Sri Steven Lim Teck Boon at +603 6092 6666 or email@example.com
- Group Deputy Managing Director - Datuk Kenix Lim Sze Way at +603 6092 6666 or firstname.lastname@example.org
If for any reason whatsoever that the whistleblower has concerns and/or reluctant to do so, then the whistleblower can report the concern to:
- Audit Committee Chairperson - Madam Tan Poh Ling at +6012 208 0628 or email@example.com
- Company Secretaries - Mr Tan Tong Lang and Mr Vimalraj A/L Shanmugam at +603 2298 0263 or firstname.lastname@example.org / mike.vimalraj @boardroom.com.my
Whistleblower who has raised concern will be informed of the person handling the matter, how the said person can be contacted and that the whistleblower be contactable for further assistance.
CONFIDENTIALITY AND PROTECTION OF WHISTLEBLOWER
A whistleblower will be accorded with protection of confidentiality of identity, to the extent reasonably practicable. In addition, a whistleblower, who is a EURO employee will also be protected against any adverse and detrimental actions for disclosure of any improper conduct committed or about to commit to the extent reasonably practicable, provided that such disclosure is made in good faith and without malicious intent. Such protection is accorded even if the investigation subsequently reveals that the whistleblower is genuinely mistaken in the reporting. However, if a concern cannot be resolved without revealing the identity of the whistleblower, e.g. providing evidence in court, a dialogue will be carried out with the whistleblower to ascertain whether and how the matter can proceed.
Upon completion of the whistleblowing process and procedures, the whistleblower would be accorded the privilege to be notified on the outcome of the disclosure.
EURO reserves the right to amend this policy from time to time.
Updated on: 22 Dec 2020