Whistleblower Policy

For the purposes of Whistleblowing, this Policy of The Pacific Insurance Berhad (TPIB) made reference to Whistleblower Policy of Fairfax Financial Holdings Limited. TPIB will attempt to ensure that this Policy is brought to the attention of all stakeholders.

Whistleblowing

1. TPIB’s Code of Business Conduct and Ethics requires every Director, officer and employee of TPIB to report any violation of the Code that 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 TPIB, 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.
2. The Chairman of Board Audit Committee shall be responsible for the effective implementation of this Policy supported by Management.
3. Identity of Whistleblower will be treated with strict confidentiality although any legal requirement to disclose to any relevant authority has to be obliged.

Reporting Procedures

Whistleblowers may lodge reports on any Improper Activity through emails or/ and physical deliveries by hand or postal services marked Private & Confidential to the following email address or the following street address:

[email protected]; or/ and

Chiarman of Board Audit Committee Chairman
c/o The Pacific Insurance Berhad
40-01 Q Sentral, No. 2A Jalan Stesen Sentral 2
KL Sentral, 50470 Kuala Lumpur, MALAYSIA

Alternatively, Whistleblowers may dial in to lodge reports on any Improper Activity via telephone numbered 03-26338686 in the form of voicemails.

Whistleblower reports through emails, voicemails or/ and physical deliveries will only be opened by Chairman of Board Audit Committee or/ and Chief Internal Auditor.

Investigation

1. Each whistleblower report will be taken seriously. TPIB 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. TPIB will ensure that every report will be attended promptly and thoroughly investigated. The actions taken by TPIB 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.
2. All particulars 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.
3. If, at the conclusion of its investigation, TPIB determines that Improper Activity has occurred, TPIB 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.
4. TPIB acknowledges that those who file reports need to be assured that their report has been properly addressed. Accordingly, subject to any legal constraints, TPIB will provide the complainant with appropriate information about the outcome of any investigation within a reasonable period (except in cases where the report was filed anonymously).

Retention

1. All documents related to the reporting, investigation, and enforcement of this Policy will be kept in accordance with applicable policies of TPIB and applicable law.

No Retaliation

1. This Policy is intended to encourage and enable directors, officers and employees of TPIB to raise serious good faith concerns without fear of adverse consequences to them by virtue of raising those concerns. Accordingly, TPIB will not carry out or, fully reasonably within its power, permit any retribution or retaliation of any kind against any individual for submitting any report in good faith.