1. Purpose
IPPFA Sdn. Bhd. (“IPPFA”) is committed to the highest standards of integrity, transparency, and ethical conduct. This Whistleblowing Policy (“Policy”) provides a safe and confidential channel for Employees and external parties to report suspected misconduct, unethical behaviour, or breaches of law or Company policies, including the Anti-Corruption and Anti-Bribery Policy (ACAB Policy).
This Policy is intended to encourage early reporting of concerns in good faith and to ensure that such disclosures are handled responsibly, fairly, and without fear of retaliation.
2. Scope and Applicability
This Policy applies to disclosures concerning the conduct of:
- directors and officers of IPPFA;
- employees at all levels (permanent, contract, temporary);
- agents, representatives, consultants, contractors, and service providers; and
- any third party acting for or on behalf of IPPFA.
Reports may be made by Employees, business partners, clients, or other external parties who have reasonable grounds to believe that misconduct has occurred or may occur.
3. Reportable Matters
A disclosure may be made in relation to any actual or suspected Improper Conduct, including but not limited to:
- bribery, corruption, facilitation payments, or kickbacks;
- breaches of the ACAB Policy or other IPPFA policies;
- fraud, theft, embezzlement, or dishonest conduct;
- misuse or misappropriation of Company funds or assets;
- financial misconduct, false reporting, or improper accounting;
- abuse of authority or serious conflicts of interest;
- serious breaches of legal or regulatory obligations;
- gross mismanagement or conduct damaging to IPPFA’s reputation; and
- deliberate concealment of any of the above.
4. Good Faith Reporting
4.1 Disclosures must be made in good faith, based on reasonable belief and not for personal gain, malice, or to avoid disciplinary action.
4.2 A Whistleblower is not required to prove the allegation. It is sufficient that the concern is honestly raised, even if it later proves to be unsubstantiated.
4.3 Knowingly false, malicious, or frivolous allegations may result in disciplinary action.
5. Protection of Whistleblowers
5.1 IPPFA will take reasonable measures to protect Whistleblowers against retaliation, victimisation, or detrimental action, including dismissal, demotion, harassment, or discrimination, provided the disclosure is made in good faith.
5.2 Protection under this Policy applies regardless of whether the disclosure results in disciplinary action or prosecution.
5.3 This Policy does not protect a Whistleblower who is found to have participated in the misconduct reported, although the disclosure may be taken into account in determining appropriate action.
6. Confidentiality
6.1 All disclosures will be treated with strict confidentiality, including the identity of the Whistleblower and the subject of the report, to the extent reasonably practicable.
6.2 Disclosure of information may occur only where:
- required by law or regulatory authorities;
- necessary for investigation or legal proceedings; or
- required for professional advice (e.g. legal or audit).
6.3 Where disclosure of the Whistleblower’s identity becomes necessary, IPPFA will endeavour to inform the Whistleblower in advance.
7. Anonymous Disclosures
7.1 Anonymous disclosures will be accepted and assessed on their merits.
7.2 However, anonymity may limit IPPFA’s ability to investigate or provide protection. Whistleblowers are therefore encouraged, but not required, to identify themselves.
8. Reporting Channels
8.1 Disclosures should preferably be made in writing and submitted to the designated Compliance Officer through the following channel:
Email: compliance@ippfa.com (to be confirmed)
8.2 Reports should include, where possible:
- a description of the concern;
- relevant dates, persons involved, and supporting information; and
- any steps already taken.
8.3 Where written reporting is not feasible, a confidential meeting may be arranged with senior management.
9. Investigation Process
9.1 All disclosures will be assessed promptly and independently.
9.2 Depending on the nature and severity of the matter, investigations may be conducted by:
- management or a designated internal committee;
- internal or external auditors;
- independent forensic or legal professionals; and/or
- regulatory or law-enforcement authorities.
9.3 Findings will be escalated to the Board or relevant committee for appropriate action.
10. Relationship with ACAB Policy
10.1 This Policy operates in conjunction with IPPFA’s Anti-Corruption and Anti-Bribery Policy (ACAB Policy).
10.2 Any disclosure relating to bribery, corruption, improper benefits, or unethical conduct under the ACAB Policy shall be reported and managed in accordance with this Whistleblowing Policy.
11. Training and Awareness
11.1 Employees will be informed of this Policy and relevant reporting channels.
11.2 Awareness of this Policy will form part of IPPFA’s broader governance and compliance framework.
12. Review and Oversight
12.1 The Board has overall oversight of this Policy.
12.2 This Policy will be reviewed periodically to ensure continued relevance, effectiveness, and alignment with legal and regulatory requirements.