Whistleblowing Policy

Asian Banking School (ABS) is committed to the highest possible standards of openness, probity and accountability in the delivery of its services.

ABS does not tolerate any malpractice, abuse or wrongdoing and it invites employees and other ABS stakeholders, who have concerns about what is happening at the workplace to come forward and voice those concerns.

This policy is introduced by ABS to enable whistleblowers to raise/escalate complaints to the appropriate level of authority on such malpractices, abuses or wrongdoings at an early stage and in an appropriate manner, without fear of being prejudiced, unfairly persecuted, victimised, discriminated against or disadvantaged.

The policy is intended to promote a culture of shared responsibility and openness among the ABS employees.

Principles

The principles underpinning the policy are as follows:

• All concerns raised will be treated fairly and properly;
• ABS will not tolerate harassment or victimisation of anyone raising a genuine concern;
• Any individual making a disclosure will retain anonymity unless the individual agrees otherwise;
• ABS will ensure that any individual raising a concern is aware of who is handling the matter; and
• ABS will ensure no one will be at risk of suffering some form of reprisal as a result of raising a concern even if the individual is mistaken. ABS, however, does not extend this assurance to someone who maliciously raises a matter he/she knows is untrue or could reasonably have known is untrue.

Scope

The policy applies to all employees, including full-time, part-time and temporary employees of ABS who lodge complaints or reports of malpractice, abuse, wrongdoing or misconduct to positions of appropriate authority within ABS (hereafter referred to as whistleblowers).

Whilst the whistleblowing policy caters mainly for employees of ABS, if complaints are received from external parties e.g., trainees, trainers, agents, independent consultants, contractors, suppliers and customers, the investigation process will be triggered and similar principles will be applied in such cases.

Policy

For purposes of this Policy, malpractice, abuse, wrongdoing and/or misconduct includes but is not limited to the issues listed below:

(a) Any unlawful act, whether of a criminal or civil nature;
(b) Misadministration (e.g. unjustified delay, incompetence, negligent advice);
(c) The use of deception to obtain an unjust or illegal financial advantage, either for the business unit or personally;
(d) Intentional misrepresentations directly or indirectly affecting financial statements;
(e) The unauthorized use of ABS funds (e.g. expenditure for improper purpose);
(f) Fraud and corruption (e.g. to solicit or receive any gift/reward as a bribe);
(g) A failure to comply with any legal obligations;
(h) Conflict of interest;
(i) Danger to the health and safety of any individual;
(j) Damage to the environment (e.g. pollution);
(k) Abuse of power (e.g. bullying/harassment);
(l) A breach of fundamental internal control;
(m) Non-professional or non-ethical behavior; and
(n) The deliberate concealment of information tending to show any of the matters listed above.

Reporting Process

Whistleblower to report

• Verbally through the whistleblower hotline at 03-2095 1399 between the hours of 9:00 am and 5:00 pm from Mondays to Fridays; or

• Via email at wbp@asianbankingschool.com.The Form at Appendix A may be used for this purpose.

Protecting the Whistleblower

The Whistleblowing Protection Officer (WPO) shall be the party responsible to execute the Whistleblower Protection Programme.

The role of WPO is to safeguard the interests of the whistleblower and ensure that the whistleblower is not subject to any form of discrimination or victimization as a result of lodging a report.

Confidentiality

Whistleblowers will be guaranteed anonymity unless the law requires disclosure of identity in the legal proceedings.

Information can only be disclosed to persons not connected with the investigation provided:

(a) The whistleblower has been consulted and consents in writing to the disclosure; or
(b) ABS or the WIO or WPO is compelled by law to do so; or
(c) ABS deems it appropriate to report the matter to the relevant enforcement agency(ies).

While a whistleblower acting in good faith may be provided with immunity from disciplinary proceedings, the malicious use of the whistleblowing policy will result in disciplinary action against the whistleblower, up to and including termination of employment.

However, in no circumstances will ABS be able nor has the power to offer any person immunity against prosecution in criminal proceedings or in civil proceedings initiated by any person.

External Disclosure

Whilst internal disclosure is encouraged at all times, an employee may be of the view that there is an exceptionally serious issue, which warrants reporting to an enforcement agency in which event, the disclosure should be made in compliance with the Whistleblower Protection Act 2010.

This disclosure must be in good faith and not for the purposes of personal gain.

You may download the full policy here.

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