Whistleblower Policy

For further information about any aspect of this Policy, you could contact either the nominated Designated Complaint Recipient ("DCR") in Generali Insurance Malaysia Berhad and Generali Life Insurance Malaysia Berhad (“Generali Malaysia”).

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1. Objective

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a) The objective of this Whistleblower Policy (‘Policy’) is to:

• support the reporting of suspected instances of improper practices or behaviour which may implicate the ethical standards or integrity of Generali Malaysia and that normal investigative and/or complaint handling procedures are not considered adequate; and
• outline the mechanisms and infrastructure in place within Generali Malaysia for the reporting and investigation of matters raised by a Whistleblower; and
• outline the measures in place to protect employees against reprisal or recriminatory action from within the organization.

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2. Scope and Coverage

a) This policy applies to all employees (including fixed term and temporary workers) of Generali Malaysia, and third parties (includes but not limited to interns, contractors, suppliers, consultants, etc.).

b) This policy provides assurance that such information from the Whistleblower will be treated in strict confidence without the risk of reprisals on the Whistleblower.

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The following communications are excluded from the scope of this Policy and the Generali Group Whistleblowing Tool:

• Request for commercial information or complaints from customers;
• Reports from Employees dissatisfied with their performance evaluation/ career path unless connected with a Breach; and
• Reports related to aspects of personal life which are not connected to the working activities.

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3. Reporting Principles

a) The whistleblowing process provides safe and confidential channels for reporting any Concerns and it is designed to facilitate the detection and management of violations of our Code of Conduct (e.g. harassment, discrimination, mobbing) which could affect the single Employee and the work environment.

b) At the same time, the whistleblowing process is critical to detect, discourage and prevent serious misconduct and breaches of law, and the related damages including direct losses (e.g., administrative sanctions, costs of defense, additional controls to be implemented, disruption of the business activities) and reputational impacts for the Company.

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4. Channels to Report

Whistleblowing Reporting and Escalation Process

Reporting whistleblowing may occur through any of the following channels:  

For detailed information on how concerns are handled see the “Process on managing reported concerns"

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The whistleblower may also make disclosures through the following channels:

a) Bank Negara Malaysia: https://www.bnm.gov.my/whistleblowing-policy

b) Malaysia Anti-Corruption Commission: https://portaladuan.sprm.gov.my

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5. Protection of the Persons Involved

Protection of Generali Malaysia Employees

a. The identity of the Whistleblower will remain confidential permanently and during all phases of the investigation except in cases arising in a criminal investigation and legal requirement.

b. Any person who reports, in good faith, a practice or an action falling within the scope of this system shall not be subject to any disciplinary action and shall be protected against any retaliatory measures from other parties, even if it is later established that the facts were inaccurate or if no further action is taken following the report.

c. Any Employee who takes any retaliatory measure against persons who have filed a report in good faith may be subject to severe disciplinary actions.

d. However, any Employee who communicates in bad faith erroneous information or who abuses the whistleblowing system in any other manner may be subject to disciplinary actions and may be sued by Generali Malaysia and/or by any person named in the report.

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Protection of the Persons Designated in a Report

a. The persons named in, or affected by, a report will be informed at the time that relevant investigations have been carried out and there is no risk of loss or alteration of evidence. Prior to this time, the affected person should not be warned of the existence of the Whistleblower, except if such warning is approved by the DCR.

b. The affected person will be informed at due time and will benefit from the rights, information and protections set out in applicable laws, including, but not limited to, the right to verify (1) the factual accuracy of any information relating to them and included in the report and (2) that they benefit from the possibility of reviewing, studying, contesting and reacting to any allegation made against them.

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Access and Rectification Rights

a. The right to access and rectification is given to any person named in a report and controlled by the DCR, by sending an email at the address listed in the above Channel's table. The DCR shall ensure that the request is processed by technically competent persons within a reasonable period of time. Such access rights do not allow the person designated in a report to be informed of the identity of the Whistleblower.