Whistleblowing Policy
The Whistleblowing channels are established to help all stakeholders raise concerns, without fear of retaliation, on any wrongdoing that they may observe in the SD Guthrie Group.
The Group takes all complaints of possible wrongdoings seriously and shall investigate the complaints, regardless of the length of services, position/title, relationship or connection of the parties alleged to the Group.
Parties can report a Whistleblowing complaint if they are aware of any Wrongdoings, including, but not limited to the following:
- Violation or risk of violation of any laws and regulations including but not limited to laws of Malaysia, European Union (EU), United Kingdom (UK), Papua New Guinea and Solomon Island (PNG & SI), Indonesia, Thailand, Singapore, South Africa, and all other countries where the Group operates and/or has business dealings;
- Acts or omissions which are deemed to be against the reputation, goodwill or interest of the Company and where public interest is at stake e.g. a risk or impending risk to public health, human safety and environmental damage;
- Human rights abuses;
- Harassment and violence, both physical and verbal;
- Fraud, including but not limited to the following:
- Acts of corruption such as conflicts of interest, bribery and kickbacks;
- Misappropriation of assets;
- Financial statement fraud;
- Criminal breach of trust;
- Abuse of power or position;
- Giving false or misleading information to internal or external stakeholders including public bodies. This includes suppression, manipulation or destruction of any material fact or information;
- Other criminal offences;
- Breaches of any Group policies and/or COBC;
- Deliberate concealment of any of the above matters or other acts of wrongdoing.
Acting in Good Faith
The Group expects all parties to act in good faith and have reasonable grounds when reporting a Whistleblowing complaint. If allegations are proven to be malicious, reckless, or with the foreknowledge that the allegations are false, parties responsible may be subject to appropriate action, up to and including legal action, where applicable. The Whistleblower protection will be revoked under the above circumstances.
Protection From Retaliation
Any party within the Group that retaliates against someone who has reported a wrongdoing in good faith may be subject to appropriate action, up to and including legal action, where applicable.
Whistleblowing Process
Upon receipt of a whistleblowing (WB) complaint, the independent WB Unit will channel the WB case for investigation to an independent party to ensure that there is no conflict of interest.
At the completion of the investigation, the investigation team will report to the WB Unit on the results of the investigation, including a conclusion on the validity of the allegations (proven/ not proven) and the proposed recommendation(s) to address the wrongdoing and/or process limitations. In ensuring that all WB cases reported are appropriately investigated and addressed, a management level WB Committee reviews the outcome of all investigations prior to tabling of all cases to the independent Governance and Audit Committee for their final deliberation before case closure.
Throughout the above process, the identity of the whistleblower is kept confidential at all times and will not be disclosed to any of the above parties. The separation of roles among the WB administrator, investigation team and oversight body provides the required check and balance on the independence of the WB reporting mechanism.
If the whistleblower is not satisfied with the way in which his/her concern has been handled, he/she can raise it with the GAC Chairman. All appeals to the GAC Chairman must be in writing (gacchairman@sdguthrie.com) and supported by valid and cogent justification. Decision of the GAC Chairman shall be final and binding.
Whistleblowing Channels
E-Form
Group Whistle Blowing e-Form
For operations in the Netherlands, should you prefer to report locally, you may lodge your report here
GAC Chairman
gacchairman@sdguthrie.com
Whistleblowing Unit
whistleblowing@sdguthrie.com
Letter
Whistleblowing Unit
SD Guthrie P.O. Box 8068, Kelana Jaya, 46781 Selangor, Malaysia.
Call
Toll Free Numbers (Malaysian Office Hours; GMT +8 Hours)
Malaysia: 1 800 22 3388
Indonesia: 007 8036 01 5252
Thailand: 1 800 011 933
Netherlands: 0800 0220 028
South Africa: 0800 993 820
United Kingdom: 0808 2344 999