For the purposes of this Whistleblower Policy, the policy for The Pacific Insurance Berhad is made references to Fairfax mean Fairfax Financial Holdings Limited and all of its subsidiaries including The Pacific Insurance Berhad.
- Pacific’s Code of Business Conduct and Ethics requires every director, officer and employee of Pacific to report any violation of the Code which is known to or reasonably suspected by that individual. Directors, officers and employees must also report any other known or reasonably suspected improper conduct or incident in relation to Pacific, including any questionable accounting, internal accounting controls or auditing matters or potential violations of the law. Any matter that should be reported is referred to as an Improper Activity.
- The Chairman of the Audit Committee shall be responsible for the effective implementation of the policy supported by the Management.
- Employees should immediately report Improper Activity:
- To their immediate supervisor, or
- To their immediate supervisor’s manager, or
- To the Chief Executive Officer, including in a situation where an employee is not satisfied with the actions taken by his or her supervisor or supervisor’s manager.
Employees can also choose instead or additionally to report Improper Activity to the Chief Internal Auditor, or Head of Human Resource.
- Officers should immediately report Improper Activity:
- To the Chief Executive Officer, or
- To the Chief Internal Auditor, or Head of Human Resource.
- Directors should immediately report Improper Activity to the Chairman of the Audit Committee.
- In addition to the above channels of reporting Improper Activity, employees could also report the Improper Activity to the regulator or law enforcement agencies.
- The contact information for the Chief Executive Officer, the Chairman of the Audit Committee and the Chief Internal Auditor / Head of Human Resource is as follows:
- Contact by email. Communications may be sent to the following email addresses, which are confidential to the respective individual addresses:
- Chief Executive Officer, email@example.com
- Chairman of the Audit Committee, (to deliver in a sealed envelope addressed as Private & Confidential)
- Chief Internal Auditor, firstname.lastname@example.org
- Head of Human Resource, email@example.com
- Contact by mail or other physical delivery.
Communications marked Private & Confidential may be mailed or delivered, addressed to the above intended recipient:
c/o The Pacific Insurance Berhad,
40-01 QSentral, No. 2A Jalan Stesen Sentral 2, KL Sentral, 50470 Kuala Lumpur, MALAYSIA Telephone: 03-26338999
Any such communication will be delivered by Pacific, unopened, to the intended recipient.
- All reports will be taken seriously. Pacific will ensure that suitable guidance is available to anyone that receives a report and that appropriate procedures are in place for investigating and tracking reports. Pacific will ensure that every report will be promptly and thoroughly investigated. The actions taken by Pacific with respect to a particular report will depend upon the nature of the report. The report may be investigated internally by management, by the Board or an appropriate committee of the Board or be referred to the police and/or the appropriate regulatory authorities. Management will report quarterly to the Audit Committee on reports received and the status of outstanding investigations.
- All information reported and disclosed during the course of an investigation will remain confidential and made available only on a need to know basis, except as necessary to conduct the investigation and to take any remedial action, and subject to any applicable law (that can compel disclosure in some circumstances). All directors, officers and employees have a duty to cooperate in the investigation of reports of Improper Activity.
- If, at the conclusion of its investigation, Pacific determines that Improper Activity has occurred, Pacific will take effective remedial action equal to the severity of the offence. This action may include disciplinary action against the accused party up to and including termination, and reporting to police and/or regulatory authorities.
- Pacific acknowledges that those who file reports need to be assured that their report has been properly addressed. Accordingly, subject to any legal constraints, Pacific will provide the complainant with appropriate information about the outcome of any investigation within a reasonable period of time (except in cases where the report was filed anonymously).
- All documents related to the reporting, investigation, and enforcement of this Policy will be kept in accordance with Pacific’s applicable policies and applicable law.
- This Policy is intended to encourage and enable directors, officers and employees of Pacific to raise serious good faith concerns without fear of adverse consequences to them by virtue of raising those concerns. Accordingly, Pacific will not carry out or, to the fullest extent reasonably within its power, permit any retribution or retaliation of any kind against any individual for submitting any report in good faith.