Policy on Whistleblowing (PWB) enables the Bank staff, external related parties (i.e vendor, customer, consultants, stakeholder etc.) to raise concerns regarding any unethical conduct or malpractice at the earliest opportunity without being subject to victimisation, harassment or discriminatory treatment, and to have such concerns properly investigated.

A whistleblower is a person who raises concerns about wrongdoings in their workplace. Whistleblower is deemed to be protected under the Policy. The identity of the Whistleblower will be kept confidential, as long as it does not hinder or frustrate any investigation.

1. Board of Directors of the Bank
2. Shariah Committee
3. Staff of EXIM Bank
4. External parties that perform services for the Bank such as the agents, lawyers, contractors, consultants, suppliers, customers of the Bank, etc.
5. Members of the public

The Bank places high value on the level of trust and integrity expected of its employees. This policy will directly support the Bank’s Core Values, Code of Ethics and Governance requirement.

1. Corruption, bribery, graft, fraud, embezzlement or dishonesty
2. Criminal offences, conflict of interest
3. Abuse of position and misuse of the Bank’s fund and assets
4. Intentional misrepresentations directly or indirectly affecting financial statements
5. Breach of any legal obligations
6. A serious breach of fundamental internal control, including policies and procedures
7. Action that could cause physical danger to another person
8. Action that could cause damage to properties/assets and environment
9. Profiteering as a result of insider knowledge
10. Forgery or alteration of any documents belonging to the Bank, customers, another financial institution, or agent of the Bank
11. Revealing the Bank’s confidential or material information without proper authorisation
12. Breach of any Guidelines related to the Code of Conduct issued by BNM for Directors, Officers and Employees in the Banking Industry

In order to carry out an investigation, details and information on the concern made by the Whistleblower should be disclosed. The Whistleblower is required to disclose his/her personal details (which will be kept confidential).

1. Name
2. Contact information – Mobile numbers, email address
3. Nature of improper conduct
4. The date and location of the incidence
5. The identity of the alleged wrongdoer
6. Particulars of witnesses, if any
7. Particulars or production of documentary evidence, if any
8. Any monetary values involved; if any
9. Other details deemed to be useful to facilitate screening and action to be carried out

Yes. The Designated Whistleblowing Officer or Designated Whistleblowing Director will determine whether the disclosure constitutes an improper conduct or criminal offence.

We are committed to keeping your identity confidential, within the bounds of the law and the investigation process. Only the Designated Whistleblowing Officer (DWO) or Designated Whistleblowing Director (DWD) will have access to your identity for the purpose of investigating your report. Please be aware that legal requirements might necessitate the disclosure of your identity in certain situations. Additionally, if legal action is pursued, your testimony may be required. It’s also important to note that if you share your disclosure with others, we can no longer guarantee its confidentiality.

Yes, you can submit a disclosure anonymously. While anonymity is respected, it’s important to understand that it might affect your eligibility for whistleblower protection.

Please provide the factual details of your concern, including what happened, who was involved, and when it took place. To ensure an accurate investigation, it’s important to avoid speculation. Be prepared to answer any necessary follow-up questions from the investigator.

No, but it is important to file a report as soon as you have enough evidence to make a good faith report. If you delay, evidence becomes stale, hampering the investigation, and then the Bank may not be able to resolve the problem.

A preliminary investigation will be initiated, and you may be contacted by either Designated Whistleblowing Officer (DWO) or Designated Whistleblowing Director (DWD)  for a confidential interview. This investigation will assess whether a full investigation is warranted and determine the appropriate parties to conduct it

• If it pertains to grievances rather than misconduct.
• If it is an anonymous report without sufficient supporting evidence.

However, if an investigation is not pursued, this does not imply that the concern will be dismissed. The Bank may still review the allegation and take appropriate action.

You can assist the investigation by providing all relevant facts and evidence. Avoid collecting information you are not authorized to access or conducting your own investigation. Be prepared to cooperate with investigators and share all information you have regarding the allegations.

You generally have the right to be informed of the outcome of your disclosure and the findings of any investigation, although there might be overriding legal or public interest reasons not to do so. However, any action taken against an employee, as a consequence of the findings of the investigation, may be personal and confidential, in which case, it cannot be disclosed.

No. You cannot disclose any information with anyone other than the Designated Whistleblowing Officer (DWO) or Designated Whistleblowing Director (DWD). Disclosing information to others could unintentionally hinder the investigation process and may impact our ability to guarantee confidentiality, particularly if your identity becomes known.

You may refer the disclosure to:

1. BNM at Bank Negara Malaysia, Jalan Dato’ Onn, P.O Box 10922, 50929 Kuala Lumpur. Or via https://bnmlink.bnm.gov.my/
2. PDRM at Polis Diraja Malaysia Headquarters, Bukit Aman, 50560 Kuala Lumpur. Or via email to rmp@rmp.gov.my 
3. MACC at MACC Headquarters, No. 2, Lebuh Wawasan, Presint 7, 62250 Putrajaya. Or via email to info@sprm.gov.my