Maybank Asset Management Group Whistleblowing Policy

1.0 POLICY STATEMENT

Maybank Asset Management Group (“MAMG”) is committed to the highest standard of ethics and integrity in its conduct of business and operations. As part of this commitment, MAMG has in place an avenue for disclosure of any improper conduct.

2.0 OBJECTIVES OF THIS POLICY

The objective of this policy is to ensure that all employees and members of the public have access to secured channels to make disclosures on any improper conduct by any member or representative of MAMG, with the assurance that there will be no repercussion against them so long as the report are made in good faith.

3.0 SCOPE

Improper conduct includes, but is not limited to:

  1. Bribery and corruption;
  2. Fraud, theft or embezzlement;
  3. Abuse of power by an employee;
  4. Conflict of interest;
  5. Breach of MAMG policy and procedure;
  6. Failure to comply with legal and regulatory obligations;
  7. Unauthorised disclosure of customer information;
  8. Breach of Maybank Group Code of Conduct; and
  9. Concealment of any of the above.

Any person who is aware of, or has reasonable grounds to suspect that, any improper conduct has been committed by an employee or representative of MAMG can make a disclosure.

4.0 DISCLOSURE CHANNELS

Disclosures can be made via phone, in person and/or in writing (physical or electronic) to any of the following Designated Recipients (“DR”):

Reporting Level Designated Recipients
Local country where MAMG operates
  1.  Head of Compliance
  2.  Head of Audit (where available)
  3. Chairman of the Board of Directors
  4.  Any independent member of the Board of Directors or member of the Audit Committee (where available)
MAMG
  1. Head of Compliance
  2. Group Internal Audit
  3. Chairman of the Board of Directors

 

Whistleblowers are encouraged to include the following information in the disclosure to facilitate investigations:

  1. Name of person(s) involved;
  2. Date and time of the event;
  3. Nature of the event;
  4. Witness to the event, if any; and
  5. Evidence of the event, if any.

5.0 CONFIDENTIALITY AND PROTECTION OF WHISTLEBLOWER

The identity of a whistleblower who made a disclosure in good faith will be kept confidential and will only be disclosed on a strictly need-to-know basis. Employees who whistleblow in good faith will also be protected by MAMG from any repercussion.

6.0 DELIBERATION OF WHISTLEBLOWING REPORTS

6.1 Any whistleblowing reports received by DRs will be required to be escalated MAMG Compliance team for investigation. However, if the reports are made against the Head of Compliance of MAMG, the respective DR receiving the whistleblowing report may escalate the report to Group Internal Audit to conduct the investigation.

6.2 Upon completion of the investigation, MAMG Compliance /Group Internal Audit will escalate to the Audit Committee of the Board (“ACB”) at MAMG for deliberation.

6.3 The ACB is chaired by an Independent Non-Executive Director and provides avenue to ensure that any reports or disclosures made via the whistleblowing channels are accorded with adequate attention, independence, investigation and remedial action, where necessary.



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