We focus on good governance practices and foster a responsible and transparent corporate management to deliver the best values to our customers.
This whistleblowing policy gives us all the opportunity, reassurance and confidence to disclose information or concerns that we may have about the conduct of others in the business or the way in which the business is run. All employees including other individuals performing functions in relation to the company, such as agency workers and contractors, are encouraged to use it.
This policy sets out the ways in which you can raise any concerns that you have and how those concerns will be dealt with.
- Disclosures will be investigated thoroughly, promptly and confidentially.
- Anyone who raises genuine concerns is considered to be a valuable asset to our company.
- You will be protected from dismissal or victimization if you follow the whistleblowing policy when making a disclosure.
- If you believe you have suffered a detriment after making a protected disclosure you can raise a grievance via the grievance procedure.
- If misconduct is found as a result of an investigation under this procedure the disciplinary procedure will be used, in addition, to any external measures.
- Maliciously making a false allegation is a disciplinary offence.
Treating Customers Fairly
Our employment policies and procedures have been reviewed to ensure that they align and support Treating Customers Fairly. In our employment policies and procedures, we seek to demonstrate the values and principles outlined in our Code of Conduct, Which provides a strong foundation for our work on ensuring that we treat our customers fairly.
Be direct, focus on what’s necessary as long as customers interests and needs are preserved.
Authenticity and honesty are key to convince and change the mindset of customers.
We understand what customers are facing; therefore, we need to speak with care and empathy.
Expand our comfort zone in the pursuit of challenging status quo, mediority.
Disrupt industry and change customers narrative towards insurance with authentic, pure insurance products.
Solving customer’s problems and ensuring their meets are fulfilled are our main priorities.
Our core value underpins everything we do. In particular with regards to the whistleblowing policy we aim to:
Act lawfully and do what is right
- Understand and comply with legal requirements
- Act professionally and with integrity
We play vigorously but fair
- We set ourselves high standards and demand a lot of ourselves
- We maintain and preserve proper business records and follow accurate, complete and fair reporting to meet our legal and financial disclosure obligations
We make decisions using the right standards
- In making a decision we ask: is it legal / the right thing to do?
- Look for objective information to make informed decisions.
Whistleblower Protection Act 2010
An Act to combat corruption and other wrongdoings by encouraging and facilitating disclosures of improper conduct in the public and private sector, to protect persons making those disclosures from detrimental action, to provide for the matters disclosed to be investigated and dealt with and to provide for other matters connected therewith.
- a criminal offence
- a miscarriage of justice
- an act creating risk to health and safety
- an act causing damage to DearTime Assets or the environment in general
- a breach of any legal/statutory obligations or company policies and procedures including its authority limits
- concealment of any of the above
Is being, has been or is likely to be, committed. It is not necessary for you to have proof that such an act is being, has been or is likely to be, committed – a reasonable belief is sufficient. You have no responsibility for investigating the matter – it is the organisation’s responsibility to ensure that an investigation takes place.
Each of the categories listed above involve some form of malpractice or wrongdoing and they are collectively referred to in the statutory provisions as the “relevant failures”.
Our policy covers a wide range of suspected or actual behaviours which cause concern and some specific examples include:
- fraud or other wrong doing
- financial irregularities
- breaches or omissions that could lead to a breach of DearTime Code of Conduct, internal compliance rules and legal or regulatory obligations
- unethical behaviour
- theft/misuse of company property or information
- abuse of expenses
If you make a disclosure, you have the right not to be dismissed, or subjected to victimisation, because you have made the disclosure.
Internal Procedure for Reporting Concerns
If you are considering whistleblowing, you are encouraged to first raise your concerns with your line manager.
If you do not feel confident about disclosing information to your line management, you can contact your Compliance Officer to discuss your concerns.
The Compliance Officer is as follows:
You can raise concerns by making a report via email and sending it to any of the following Compliance Officers:
Any email sent to the Compliance Officer is duly indicated as “whistleblowing” and will be dealt strictly within the provisions of this policy.
Investigation of Reported Concerns
All concerns reported will be investigated thoroughly, promptly and in ways which protect your identity if this is what you wish.
You are advised to make your disclosures in writing and to provide sufficient details which include the following:
- the type or description of improper conduct;
- the name of individuals who have committed or are involved in the improper conduct; and
- the ‘how’, ‘what’, and ‘where’ in relation to the improper conduct including supporting documents or evidence, if any.
You are encouraged to provide their identities or contact details to facilitate Compliance to clarify or obtain further information for purposes of further investigation into the improper conduct. Any person who elect to remain anonymous is advised that no whistleblower protection will be accorded and DearTime’s ability to investigate the alleged improper conduct is limited to the extent of the contents of the report received.
You will be notified once the investigation has been completed unless the report was submitted anonymously.
If you don’t believe the concern can be dealt with internally or on conclusion of the investigation, you don’t reasonably believe that the appropriate action has been taken you should report the matter to the appropriate authority which includes:
BNMLINK (Walk-in Customer Service Centre)
Ground Floor, D Block
Jalan Dato’ Onn
50480 Kuala Lumpur
BNM TELELINK (Contact Centre)
Bank Negara Malaysia
P.O. Box 10922
50929 Kuala Lumpur
Operating Hours: 9.00 a.m. – 5.00 p.m. (Monday – Friday)
You are protected if you reasonably believe that the subject matter properly falls within the prescribed person’s remit, the disclosure is made in good faith and that the information and any allegation in the information are substantially true.
Where you can find out more
To find out more, or if you have any questions, you can talk to your manager or your Compliance Officer and you can seek advice and information on company policies from Compliance.
What our whistleblowing policy is not for
It is not to be used to:
- Act maliciously or make deliberately false allegations
- Seek personal gain
- Disagree with decisions made by management
- Challenge practices and policies with which you disagree where there are other channels open to you (e.g. line management, grievance procedure, harassment & bullying policy, and UFS or Unite).
You should be aware that the policy will apply where a disclosure is made in good faith and where you reasonably believe that the information disclosed and any allegation contained in it are substantially true. If any disclosure is made in bad faith (for instance, in order to cause disruption within the organization), or concerns information which you don’t substantially believe is true, or if the disclosure is made for personal gain, then such a disclosure will constitute a disciplinary offence.
Please remember that DearTime regards anyone who raises genuine concerns as an asset to our business.
Exclusion from Protection
Potential whistleblowers are also reminded that there may be instances wherein their protection would be revoked or excluded. The whistleblower protection does not extend to the following disclosures and will be revoked pursuant to section 11 of the Whistleblower Protection Act 2010:
- where the disclosures of improper conduct which are –
- frivolous or vexatious;
- principally questioning the merits of government policy, including policy of a public body;
- known to the whistleblower to be false or untrue; or
- made solely or substantially to avoid dismissal or other disciplinary action;
- where the whistleblower has participated in the improper conduct so disclosed;
- where the whistleblower commits an offence under the Whistleblower Protection Act 2010; or
- where the disclosures of improper conduct which contain information specifically prohibited from being disclosed under any written law such as the Official Secrets Act 1972.
Any person who makes a disclosure of improper conduct, knowing or believing that any material statements in the disclosure is false or untrue commits a criminal offence under the Whistleblower Protection Act 2010.
I have suspicions that a colleague has not followed the correct FSA procedure when dealing with a customer, what should I do?
In the first instance you should raise your concerns with your Manager. If you do not feel confident about disclosing information to your line management you can contact your Compliance Officer to discuss your concern.
After making a disclosure I believe I have suffered a detriment – can I make a formal complaint?
Yes, you should do this by getting in touch with our Company Secretary (email@example.com) to send your grievance/complaint to the Chairman of the Audit Committee.
I am concerned that I may suffer repercussions if I do report an incident, how can the Company ensure this will not happen?
If you do make a disclosure in good faith and where you reasonably believe that the information disclosed and any allegation contained in it is substantially true, you have the right not to be dismissed or subjected to victimisation for making the disclosure and DearTime will consider disciplinary action if it is found that this has happened as a result of the disclosure being made.
If I do report an incident, will I be kept informed with developments?
You will be advised once any investigation has been completed.
What should I do if I feel an incident has not been dealt with appropriately by the Company?
If you feel this is the case, you can report your concerns to the appropriate authority which could include Bank Negara Malaysia.
Where can I find out more about Whistleblowing?
The Whistle-blower Protection Act 2010 is available online at https://www.ilo.org/dyn/natlex/docs/ELECTRONIC/106318/130371/F1610672104/MYS106318.pdf
Ensure that relevant, accurate, balanced and timely information is made. Read more.
Anti Fraud Policy
DearTime Berhad’s vision is covering every human life directly with life insurance, and restoring the quality and quantity of life for those in times of need. Given this, the company has no appetite for Fraud be it internal or external. In this respect we have in place the following anti-fraud measures:
- A comprehensive Anti-Fraud Policy
- “whistle blowing policy”. If you have information on or suspect of fraudulent practices, regardless of who it may be within DearTime Berhad, or any of our partners, or our Policyholders or Suppliers please let us know immediately via our secure email firstname.lastname@example.org. We ensure full confidentiality of information provided and immediately investigate issues raised.
- Where appropriate and necessary conduct checks with a licensed credit referencing agency and a record of any such search on an insured will be retained in the file. This information may also be exchanged with other insurers through various authorized and approved databases to ensure accuracy, mindful of the Data Protection Act. This information can also be disclosed to regulatory authorities in response to formal requests.
- Our Compliance team investigate all fraudulent cases
- We maintain close working relationships with the following enforcement authorities including Bank Negara Malaysia :-
- Polis Diraja Malaysia
- Malaysia Communication and Multimedia Commission
- Ministry of Domestic Trade, Co-operatives and Consumerism
- Securities Committee Malaysia
- Cyber Security Malaysia
- In Dealing with Fraudulent Cases – We are guided by our internal policy and procedure and our staff who are well trained to detect the possibility of fraud. We will handle all fraud investigations expeditiously and swift and tern action will be taken if indeed there is evidence of fraud. DearTime would not hesitate to take legal action against fraudsters who target the company, its staff or customers.