For further information about any aspect of this Policy, you could contact either the nominated Designated Complaint Recipient in Generali Insurance Malaysia Berhad and Generali Life Insurance Malaysia Berhad (“Generali Malaysia”).
a) The objective of this Whistleblower Policy (‘Policy’) is to:
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.
a) Misconduct can take many different forms but for ease of data analysis, reporting and reference, Generali Malaysia classified the allegations into seven categories presented in the following table. Note that this list is not intended to be considered exhaustive:
Any concerns related to employees’ management & oversight and linked to misconduct while hiring and promoting, employing administrating employee benefits or terminating, dismissing, retiring, etc. This includes breaches of labour law, harassment, discrimination, inappropriate behaviour at work, etc.
Misappropriation of assets
Any fraudulent disbursement (fictitious invoices, payroll fraud schemes, fraudulent expense claims, etc.), theft, misuse or abuse of company assets (such as phone, computer) or cash larceny (petty cash and other funds).
Leakage or theft of data.
Financial statement fraud
Any misrepresentation, falsification, concealment, misstatement or omission of financial records including “cooking the books”, overstating or understating revenue, inflating expenses, etc.
Other fraudulent statements
Any distortion, deception, disguised, misstatement or omission of non-financial management information such as HR strategic, commercial, asset management, etc.
Corruption, bribery, extortion
Offering, making, soliciting or accepting any payment, gift or other inducement, from a private individual or government official, for the purpose of improperly obtaining or retaining business, or to secure or provide an improper business advantage.
Note: This list is simply to facilitate reporting of the events in a consistent manner across Generali entities; it is not intended that this list be considered as a comprehensive list of subjects upon which whistle-blowing events can be made. If it is not clear which category a report should fall into then guidance should be sought from the relevant Designated Complaint Recipient (DCR).
Whistleblowing Reporting and Escalation Process
Reporting whistleblowing may occur through any of the following channels:
Email to local DCR
Submit your allegations to the following email address:
Generali Insurance Malaysia Berhad Whistleblower Hotline:
Submit your allegations to the following email address:
Generali Life Insurance Malaysia Berhad Whistleblower Hotline:
Postal service or Internal Mail
In such case to be able to guarantee the confidentiality, it is required that documentation is placed in a sealed envelope with the indication “private & confidential”
Have a conversation with one of the following person authorised to receive communication:
Note: Any communication carried out anonymously will be considered for verification only if they are deemed particularly serious and contained an appropriate detailed content, which would allow for an investigation to be proceeded.
a) There is no specific format required for the Whistleblower Report, but the report should include sufficient information to allow investigation to be conducted, such as:
i. The name of the concerned party(ies)
ii. Sufficient details of the incidence with supporting materials, if any
iii. Contact details (e.g. an email address or telephone number) for the DCR to follow-up.
b) Should a Whistleblower wish to remain anonymous it is important that they provide either enough information to facilitate a thorough investigation into the matter(s) being raised or anonymised contact details (e.g. email address) for follow-up.
c) The Whistleblower should make the report in good faith and have reasonable grounds to suspect the information he/she is reporting indicates misconduct occurred. Deliberate false reporting will not be tolerated, and anyone found making a deliberate false report will be subjected to disciplinary action, which could include dismissal.
d) DCR will have direct and unrestricted access to financial, legal and operational assistance when this is required. All employees of Generali Malaysia are required to co-operate in investigations.
e) Under certain circumstances, the member of staff may be contacted for additional information to clarify the notification made.
f) Any individual who is the subject of an allegation and is under investigation should be given a fair opportunity to respond to the allegation, if appropriate. The person who is whistle-blown against must not be notified of the allegation against them until such time that this has been approved by the relevant local Chief Compliance Officer.
g) Confidentiality must be ensured at all times and every reasonable efforts must be taken to keep the Whistleblower’s identity confidential. This is critical in ensuring that no reprisal or recriminatory action is taken against the Whistleblower. Revealing the existence of an investigation or details contrary to this policy could result in disciplinary action.
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.
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.
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.