Additional Information : Whistle-blowing policy
The Company has adopted a whistle-blowing policy which serves as an early warning system to assist the Company in detecting wrongdoings and taking early corrective action. It is the Board’s belief that having a whistle-blowing procedure in place will increase investors’ confidence in the Company and is in line with the Company’s sound corporate governance practices.
The whistle-blowing policy is one of the key provisions in the Standards of Business Conduct and was established in 2004 and is reviewed by the Company for enhancements from time to time. The whistle-blowing procedure enables employees to make their concerns known without fear of retaliation and with the knowledge that their complaints will be acted upon and their identity is kept confidential.
To further enhance the whistle-blowing procedure framework, the Company had put in place the Procedures on Incident Reporting and Investigation (Incident Procedures). The Incident Procedures is made available to all employees via the Company’s intranet. The Incident Procedures formally set out the process and procedures for reporting, investigation and evaluation of any suspicion of wrongdoing or misconduct committed by any employee of the Company and non-employee who is a business partner/service provider of the Company in a prompt and effective manner. The evaluation of any incidences reported is conducted by a formal evaluation committee comprising a majority of the Company’s Leadership Team (EVT). The EVT is tasked to effectively drive and evaluate the investigation of any reported incident and decide on appropriate action to be taken arising from the investigation and is guided in its review of all investigation of incidents reported by a set of standard operating procedures (EVT SOP). The EVT SOP amongst others sets out clearly the roles and responsibilities of the EVT, the Head of Investigation, the Head of Legal and the timelines for the review to be completed to ensure that speedy action is taken after an incident hasbeen reported.
All incidents reported were investigated by an investigation team comprising of senior managers working closely with the EVT to ensure that all cases which have been reported or discovered are investigated upon promptly. The reports of investigation are then sent to the EVT for review and evaluation and if the case warrants it, police reports will be made, domestic inquiries will be conducted and appropriate disciplinary action including freezing of increments, issuance of warnings and termination will be taken. If any control weaknesses are identified by the investigation team such weaknesses will be rectified to prevent future occurrences.
The outcome of the investigations and the actions taken by the Company will be reported to the Audit Committee of the Company and further submitted to the Regional Audit Committee for the British American Tobacco p.l.c’s Main Board Audit Committee. The Company maintains a register of all whistle-blowing and breach of Standards incidences.
With the presence of the whistle-blowing procedure, Incident Procedures and stringent control measures, the Company detected seven incidents involving areas such as theft and the gross losses suffered by the Company arising from the incidents reported in 2013 were approximately RM77,687.62. Four employees were dismissed from the Company’s employment as a result of their misconduct. This is an improvement from 2012 where eighteen incidents were reported and the gross losses suffered by the Company arising from those incidents were approximately RM547,700.00.