PURPOSE
Our company, Panasonic Manufacturing Malaysia Berhad (the “Company”) is committed to create value and contribute to society’s progress and development through our business activities. As a responsible corporation, we will commit to conduct our business activities with integrity, a law-abiding spirit and the highest ethical standards.
This Whistleblowing Policy aims to
establish a robust, transparent and accountable communication channel for Employees and Stakeholders of our company to voice their concerns in an effective, responsible and secured manner when they become aware of actual or potential wrongdoings that will cause us to fall short of our economic, environment and social responsibilities; and
enable us to take swift, fair and effective corrective actions that will enable us to comply with our economic, environment and social responsibilities and maintain the support and trust of Employees and Stakeholders.
DEFINITIONS
In this Whistleblowing Policy, the following terms have the following definitions:
“Code of Conduct” means the Panasonic Code of Conduct;
“Employees” means all board of directors, executive officers, members of management, regular employees and contracted employees having employment relationships with our company, as well as temporary staff and seconded employees working under the control and supervision of our company;
“Employee Grievances” applies to personal dissatisfaction or complaints by Employees that are related to their employment and working conditions;
“Stakeholders” means third party suppliers, contractors, agents, consultants, distributors, customers and such other business partner which has direct or indirect business dealings with our company;
“Whistleblowing Governance Panel” shall have the meaning described in Section 4.2;
“Whistleblowing Investigation Team” shall have the meaning described in Section 5.1;
“Whistleblowing Policy” or “Policy” means this whistleblowing policy, including any subsequent revisions and supplemental guidelines;
SCOPE AND APPLICATION
This Policy provides a system that enables our company’s Employees and Stakeholders acting in good faith to raise concerns and disclose actual or potential wrongdoings or misconduct in our company. These wrongdoings or misconduct include but are not limited to (i) violation of laws and regulations, (ii) unethical behavior or breach of Code of Conduct, (iii) giving, solicitation or acceptance of bribes, (iv) acts that adversely affect the interests or values of shareholders and Stakeholders, (v) unauthorized disclosure or sale of company information, (vi) falsification of reports or documents, (vii) fraud, theft, embezzlement or misuse of company assets, (viii) improper or undesirable personal behavior or misdeeds which seriously impacts our company’s business or reputation, (ix) sexual or other forms of harassment in the workplace; and (x) attempts to cover any of the aforementioned.
Employees and Stakeholders who raise their concerns in good faith in accordance with this Policy are protected from reprisals within the limits of the law and assured that all reported cases will be objectively investigated on a best effort basis and appropriate remedial measures taken where warranted. This Policy is not intended to restrict or otherwise govern legal rights and obligations which Employees and Stakeholder have, or may have, in relation to the subject matter of the whistleblowing report.
This Policy is not intended for Employees to lodge Employee Grievances or appeal on disciplinary procedures. Employees can report Employee Grievances or lodge appeals on disciplinary procedures through our company’s human resources department.
Employees and Stakeholders should exercise due care to ensure that the information in their whistleblowing report is accurate and truthful. No action will be taken against Employees or Stakeholders who make an allegation in good faith which is not confirmed by subsequent investigation. But this protection may be revoked if Employees and Stakeholders misuse or abuse the Whistleblowing Policy by making false, frivolous, malicious or vexatious allegations.
HOW TO MAKE A WHISTLEBLOWING REPORT
Employees and Stakeholders should report their concern at the earliest opportunity so that corrective action can be taken as soon as possible.
The monitoring and execution of this Whistleblowing Policy will be placed under the supervision of the Whistleblowing Governance Panel comprising the following:
(i) Members of our company’s Audit Committee; and
(ii) Managing Director of our company.
The Audit Committee Chairman shall be the chair for the meeting of the Whistleblowing Governance Panel where a quorum of no less than two (2) members are present and in his absence, another member of the Audit Committee shall be the chair.
Where any member of the Whistleblowing Governance Panel is the subject of the investigation, the member will be reclused from attending any meeting of the Committee.
Employees and Stakeholders have the option to make whistleblowing reports in strict confidence through any of the following channels:
| Reporting Mode | Contact Details |
|---|---|
| Letter to Audit Committee Chairman | Panasonic Manufacturing Malaysia Berhad 3, Jalan Sesiku 15/2 40200 Shah Alam, Selangor Attention: Audit Committee Chairman |
| Online Submission | http://panasonicapac.ethicspoint.com |
| Electronic mail (email) | ml_compliance_pmma@my.panasonic.com |
| Global Hotline | NAVEX Global (24 hours, 365 days) 1-800-81-8923 |
Employees and Stakeholders making a whistleblowing report should disclose their (i) full name, (ii) NRIC and/or Employee Number (if applicable), as well as (iii) contact details such as telephone number and email address. This will enable our company to accord the person making the whistleblowing report necessary protection under this Policy and also obtain more details pertaining to the whistleblowing report.
Reports may be made on an anonymous basis. However, natural justice usually requires that the details and identity of the Employee or Stakeholder submitting the whistleblowing report be disclosed in any disciplinary investigation or action to be taken against the person(s) who is a subject of the complaint in the whistleblowing report. Anonymous whistleblowing reports will therefore be considered at the discretion of the Whistleblowing Governance Panel. In exercising this discretion, the Whistleblowing Governance Panel will consider (i) the seriousness of the issues raised, (ii) credibility of the whistleblowing report, and (iii) likelihood of confirming the allegation from the relevant sources.
Whistleblowing reports should include the following disclosures: (i) background and history of the concern (giving relevant dates), (ii) reason for the concern, and (iii) identity of the person(s) committing the alleged wrongdoing. Insufficient details in the whistleblowing report may impede the investigation and resolution of the concerns raised.
WHISTLEBLOWING INVESTIGATION
Upon receipt of the whistleblowing report, the Whistleblowing Governance Panel will as soon as practicable establish a Whistleblowing Investigation Team comprising appropriate and suitably qualified personnel who is independent of the concern disclosed in the whistleblowing report to conduct the investigation in a fair and objective manner and at its discretion, consider involving any other or additional officer of the Company and/or Committee and/or an outside agency for the purpose of investigation. The investigation by itself would not tantamount to an accusation and is to be treated as a neutral fact finding process. If the Whistleblowing Investigation Team finds that the alleged wrongdoing or misconduct is true, our company will take appropriate actions including disciplinary action, termination of contract and establishing new controls to prevent recurrence of the wrongdoing or misconduct in our company.
A member of the Whistleblowing Governance Panel or an officer appointed by the Whistleblowing Governance Panel will within 10 calendar days, contact the person who submitted the whistleblowing report to (i) acknowledge that the report has been received, and (ii) indicate how the report will be dealt. The Whistleblowing Governance Panel is not obliged to contact the persons who submitted the whistleblowing report anonymously, exclude contact details or do not report in good faith.
The Whistleblowing Governance Panel will keep a record of all steps taken in response to each whistleblowing report received as well as how the concerns raised were resolved.
The Whistleblowing Governance Panel will report their findings to the Audit Committee and Board of Directors.
CONFIDENTIALITY AND SAFEGUARDS
All whistleblowing reports will be treated as confidential. The identity of the Employee or Stakeholder who submitted the whistleblowing report will not be disclosed without prior consent, unless required by law. The Company undertakes to treat all disclosures in a confidential and sensitive manner and to protect the identity of the whistleblower.
This Whistleblowing Policy offers protection within limits of the law and to the extent reasonably practicable to Employees and Stakeholders who submit whistleblowing reports internally in good faith, even if the allegations prove to be unfounded or mistaken. These Employees and Stakeholders will be appropriately protected from internal disciplinary actions (if applicable), dismissal, harassment, victimization or informal pressures. No protection from internal disciplinary action will be offered if Employees do not adhere to the procedures for whistleblowing and disclosures in this Policy.
This Whistleblowing Policy will be reviewed annually and amended from time to time by Panasonic Manufacturing Malaysia Bhd.
Any questions about the content or application of this Policy should be addressed to Q&A. compliance_pmma@my.panasonic.com
Click here to download Whistle Blowing Report E-Form.