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 (firstname.lastname@example.org) 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 email@example.com. 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.
Anti-Bribery & Anti-Corruption (ABAC) Statement
DearTime Berhad (“DearTime”) is committed in conducting business and servicing its customers and customers with high ethical standards and integrity. Accordingly, DearTime adopts a zero-tolerance policy against all forms of bribery and corruption.
DearTime is committed to ensure that its management and staff act with the highest level of professionalism, act fairly and with integrity in all its dealing and expects that all its Third Parties uphold the highest standard of integrity in performing work or services for or on behalf of DearTime.
The purpose of this Anti-Bribery and Anti-Corruption (“ABAC”) Statement is to set out the responsibilities of the management and staff of DearTime in combating bribery and corruption issues.
This Statement applies to all individuals working for and on behalf of DearTime at all levels, whether permanent, fixed-term or temporary, the management of DearTime (“Staff”) and Third Parties acting on behalf of DearTime.
Although this Statement is specifically written for DearTime’s staff and the management of DearTime, DearTime expects that all Third Parties engaging with DearTime to read, understand and comply with the requirements set out in this ABAC Statement. No waivers or exceptions will be granted for practices that deviate from DearTime’s ABAC Statement.
All staff of DearTime are expected to exercise proper judgement and behave in a manner consistent with the general principles, as follows:
- always exercise proper care and judgement;
- avoid conflict of interest;
- conscientiously maintain the highest degree of integrity and ethics; and
- complies fully with all the applicable laws, regulatory requirements on anti-bribery and anti-corruption and with all regulations, procedures, and policies issued by DearTime.
Gift And Hospitality
As a general principle, all gifts and hospitality received and/ or given by DearTime during the course of business dealings are subject to the stringent requirements provided in this ABAC Statement and all internal operating guidelines/procedures issued by DearTime. Under no circumstances shall any gifts or hospitality be received or given with the intention to gain a business advantage or induce unjust influence. All gifts and hospitality irrespective of their value given and /or received by DearTime’s staff, including their family members must be reported to the Compliance Officer. All records must be maintained regardless if the request is approved or denied.
B. Prohibited Gifts and Hospitality
The Staff are prohibited from soliciting, giving and should immediately decline, reject and return (if received) the following:
- any gift of cash or cash equivalent which includes but is not limited to gift cards, vouchers, discounts, coupons, loans, shares, securities, commission, digital assets;
- gift or hospitality that is excessive, lavish, inappropriate, illegal or given in response to, in anticipation of, or to influence a favorable business decision, particularly from parties engaged in a tender or competitive bidding exercise (for e.g. contractors, vendors, suppliers and etc.).
C. Gift and Hospitality Register
All business functions in DearTime are required to report any gifts or hospitality received or given to the Compliance Officer who maintains a companywide gift and hospitality register (hereinafter referred to as “Gift and Hospitality Register”).
Facilitation Payments and Kickbacks
DearTime does not make, and will not accept any facilitation payment or kickbacks of any kind, whether directly or indirectly. Facilitation payment refers to any sums of unofficial payment made to secure, expedite or facilitate an ordinary governmental action, process or procedure to a government official (either locally or internationally). Kickback refers to an illicit payment or commission made in return for facilitating a transaction, procurement of a project or furthering of business dealing.
Political Donations and Contributions
DearTime does not make any donations, contributions or give financial supports to any public body, political parties, individuals engaged in politics or politically motivated projects.
Charitable Donation and Sponsorships
DearTime may make donations or provide financial support to organizations (including charity organisations) that are properly registered with the local government authority. The chosen organisation should not be connected to any government agencies, public body, public officials or persons that may use his or her influence to give special preference to DearTime.
Before any charitable contributions or sponsorships can be made, compliance due diligence should be performed on the chosen organisation and reported to DearTime’s Compliance Officer and the Chief Executive Officer.
All charitable contributions or sponsorships must be properly recorded with proof of receipt from the organisation. Under no circumstances may the charitable contributions or sponsorships be made in cash. Charitable contributions or sponsorships must not create the appearance of a bribe, kickback or other corrupt practice, and should never be used to directly or indirectly to procure future business dealings or otherwise be made with the intent to obtain or retain business, secure an improper advantage, or induce anyone to act improperly.
Dealing with Third Parties
DearTime expects that all Third Parties acting for or on its behalf to share the same values and ethical standards as their actions can implicate DearTime legally and tarnish its reputation. Therefore, when engaging Third Parties, DearTime is obligated to conduct appropriate counterparty due diligence to understand the business and background of the prospective business counterparties before entering into any arrangements with them to ensure that such counterparties subscribe to an acceptable standard of integrity in the conduct of their business.
If at any point during the due diligence exercise or in the dealings with a Third Party, there are conflicts of interest or “red flags” are raised, these warrant further investigation and must be sufficiently addressed before the engagement of the Third Party can progress.
Examples of common “red flags” involving Third Parties include:
- the transaction involves a country known for a high incidence of corrupt payments;
- family, business or other “special” ties with government officials;
- a reference check reveals a flawed background or a reputation for getting “things done” regardless of the circumstances or suggests that for a certain amount of money, he can fix the problem;
- objection to anti-bribery representations and warranties in commercial agreements or negative response when told of such requirements;
- convoluted payment arrangements such as payment in cash, payment to a third party or into accounts in other countries or requests for upfront payment for expenses or other fees;
- expertise of the business counterparties does not match the nature of the current business transaction to be entered into;
- the Third Party requires that their identity not be disclosed as part of the business transaction; and
- inadequate credentials for the nature of the engagement or lack of an office or an established place of business.
DearTime requires its Staff to use good judgment in assessing the integrity and ethical business practices of Third Parties.
Offence Under The Malaysian Anti-Corruption Commission Act 2009 (“The MACC Act”)
A. Receives or Gives Gratification
- Under Section 16 of the MACC Act, any person who by himself or by or in conjunction with any other person corruptly solicits or receives or agrees to receive for himself or any other person or corruptly gives, promises or offers to any person whether for the benefit of that person or of another person, any gratification as an inducement to or a reward for, or otherwise on account of (i) any person doing or forbearing to do anything in respect of any matter or transaction, actual or proposed or likely to take place or (ii) any officer of a public body doing or forbearing to do anything in respect of any matter or transaction, actual or proposed or likely to take place, in which the public body is concerned, commits an offence.
- Any person who commits an offence under Section 16 of the MACC Act, shall on conviction be liable to imprisonment not exceeding twenty (20) years and a fine not less than five (5) times the sum or value of the gratification is capable of being valued or of a pecuniary nature, or ten thousand ringgit (RM10,000.00), whichever is higher.
B. Offence by a Commercial Organisation
Section 17A of the MACC Act provides that a commercial organisation commits an offence if a person associated with the commercial organisation corruptly gives, agrees to give, promises or offers to any person any gratification whether for the benefit of that person or another person with intent to obtain or retain a business for the commercial organisation or to obtain or retain an advantage in the conduct of the business for the commercial organisation.
On conviction, a commercial organisation can be liable to a fine of not less than ten (10) times the sum or value of the gratification which is the subject matter of the offence, or One (1) million ringgit (RM1,000,000.00), whichever is higher or imprisonment for a term not exceeding twenty (20) years or to both.
Where an offence is committed by a commercial organisation, its director, controller, partner, officer or any person who is concerned with the management of the affairs of the company is deemed to have committed the offence unless he/she can prove that the offence was committed without his/her consent and he/she has exercised proper due diligence.
DearTime strongly encourage any Staff or Third Party acting for and on behalf of or conducting business dealings with DearTime to notify or report to the management of DearTime or directly to the authorities on any improper conduct. Section 7 of the Whistleblower Protection Act 2010 provides protection to whistleblowers that makes a report to an enforcement agency and extends such protection to any person related to or associated with the whistleblower provided that such disclosure is not specifically prohibited by any written law.
For further information, please refer to DearTime’s Whistleblowing Policy here.
Any Staff who breaches this ABAC Statement may face disciplinary action, which could result in dismissal for gross misconduct. DearTime reserves the right to terminate contractual relationship with any Third Party acting for and on behalf of or conducting business dealings with DearTime if there is a breach of this ABAC Statement.
Review, Monitoring and Implementation
DearTime ensures that the management continuously monitors the effectiveness and reviews the implementation of this ABAC Statement at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are implemented on forthwith basis. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in eliminating any risks of bribery and corruption.
In addition to reviews, DearTime is committed in ensuring strict implementation and enforcement of the anti-bribery and anti-corruption framework within DearTime. These monitoring and enforcement steps may include the form of internal or external audits carried out by external independent agency.
DearTime further seeks to conduct continual evaluations and identify competent persons and establish proper compliance functions to perform the monitoring and implementation of anti-bribery and anti-corruption measures within DearTime.
DearTime ensures that all matters regarding the prevention of bribery and corruption which includes but is not limited to risk assessment, proposed improvements and amendments to process and procedures, annual reviews of policies, complaints, disciplinary actions taken on prohibited conducts is properly documented and recorded.
Training and Communication
Training on this ABAC Statement is provided to all Staff and DearTime’s approach to bribery and corruption will, where appropriate, be communicated to any Third Party acting for and on behalf of or conducting business dealings with DearTime.
DearTime regularly communicates the requirements and obligations under this ABAC Statement and related policies through various mediums and platforms which includes but is not limited to emails, code of conduct, DearTime’s website and internal platforms.
DearTime reserves the right to amend, modify or update this ABAC Statement periodically and at any time by updating and publishing the effective date of the release of the new versions hereof through an internal circulation to the Staff or by making it available in DearTime’s website.
If you have any questions or require further information about any aspect of this ABAC Statement, please contact us at firstname.lastname@example.org.