Whistleblowing Policy

1. INTRODUCTION

1.1 I-SERVE PAYMENT GATEWAY SDN BHD (201501003085 (1128417-K)) (referred to as “i-Serve”) and its subsidiaries (collectively referred to as the “Group”) is committed to ensure its business and operations are conducted in a consistently ethical and legal manner.

1.2 In line with this commitment, i-Serve has put in place the Whistleblowing Policy and Procedures to provide a secure and confidential avenue for disclosure of any improper conduct as well ensuring protection to Whistleblowers.

1.3 Whistleblowers are persons including employees of i-Serve as well as all external parties who have business relationships with i-Serve. These parties include customers, suppliers, vendors, contractors, applicants of employment, business associates, and the general public making disclosure in good faith on any improper conduct in i-Serve.

2. SCOPE

2.1 Whistleblowing is an act of voluntary disclosure of inappropriate, unethical or unlawful behaviour or practices by the management, employees including appointed vendors or service providers which may cause serious damage to i-Serve.

2.2 Complainant can report a whistleblowing incident if he/she is aware of any misconduct or wrongdoing, including but not limited to the following Reportable Incidents:

REPORTABLE INCIDENTS
Type	Description
Fraud	Relates to the use of deception or misrepresentation to obtain an unjust advantage. It can also involve the theft or misappropriation of i-Serve’s property, funds and/or assets.
Corrupt Conduct	Corrupt conduct can take many forms including seeking, obtaining or offering secret commissions, kickbacks, theft, embezzlement, forgery, misuse of information, involve in business and transactions which are in conflict with the interest of i-Serve, documents or materials acquired in the course of employment and dishonest performance of functions.
Questionable Accounting and Audit Practices	Refers to practices that do not comply with accounting or audit standards, or are fraudulent, dishonest or deceptive.
Adverse Behaviour	Involve illegal behaviour, such as violence or threatened violence, criminal damage against property, sexual harassment, bullying, unfair treatment and serious breach against i-Serve’s polices or regulatory requirements.

3. ACTING IN GOOD FAITH

3.1 The whistleblower is responsible to ensure that the disclosure is made in good faith, free from malicious intent, and is not in aid of personal gain(s) or with a vested interest. This is also not a channel for taking up any personal grievances.

3.2 Any disclosure is expected to be made based on reasonable belief or grounds that the information or allegations are substantially true. However, reports made that are frivolous, not true, misleading or made mala fide or with malicious intent may result in disciplinary or other action.

4. WHISTLEBOWING CHANNEL

4.1 A complaint may be raised by submitting the report through email at whistleblowing@i-serve.com.my.

4.2 All whistleblowers are encouraged to make a report via the format attached in Appendix 1 – Form of Disclosure of Reportable Incidents. The format is introduced to ensure all relevant information are disclosed.

4.3 The whistleblowing channel above is secure, confidential and accessible only by the authorised personnel.

4.4 Alternatively, the whistleblower may report directly to the relevant government or regulatory authorities and enforcement agencies in Malaysia as prescribed by the Whistleblower Protection Act 2010 such as Bank Negara Malaysia (BNM), Malaysian Anti-Corruption Commission (MACC), Police, etc.

4.5 A whistleblower who wishes to withdraw his/her disclosure is required to write to the same email, together with supporting reason(s) for the withdrawal. Notwithstanding such withdrawal, i-Serve reserves the right to proceed with its investigation on the matter arising from such disclosure.

5. DISCLOSURE REQUIREMENTS

5.1 The report made should contain the relevant information and be as specific as possible in order for i-Serve to be able to effectively evaluate and investigate the complaint. The details should include:

details of complainant;
details of the parties involved;
dates or period of time during which the alleged act/ behaviour or incident occurred; and
evidence substantiating the complaint, where possible

5.2 Complainant is encouraged to identify themselves and provide their contact details when making a report to enable the relevant parties conducting the investigation to contact the whistleblower for further information.

6. INVESTIGATION

6.1 Upon verification of genuine cases, prompt investigation will be carried out.

6.2 Depending on the nature and severity of the complaints, i-Serve may undertake varying levels of inquiry either through i-Serve’s relevant departments or an independent inquiry.

6.3 i-Serve at its discretion, may keep the whistleblower informed of the outcome of any investigation within constraints of maintaining confidentiality or observation of legal restrictions.

7. PROTECTIONS TO WHISTLEBLOWER

7.1 It is i-Serve’s policy to provide the whistleblower protection in term of confidentiality of information, including his/her identity of the whistleblower as well as safeguarding him/her from any act of interference that may be detrimental for making the disclosure in good faith.

7.2 There may be certain circumstances where the identity of the whistleblower may need to be revealed on a need-to-know basis (e.g. required under the law). If such a situation arises, i-Serve shall seek the consent of whistleblower before proceeding with the case.

7.3 The protection will be removed if it is found that the whistleblower was also involved in the improper conduct, or if he/she is found to have made the disclosure in bad faith.

8. CONSEQUENCES OF NON-COMPLIANCE

8.1 i-Serve will take serious action against all parties who have acted in violation of this policy including but not limited to:

reprimand, take disciplinary action, impose punishment as appropriate;
termination or suspension of employment;
report to the relevant authorities (if applicable);
any other action deemed appropriate by i-Serve.

9. REVIEW OF THE POLICY

9.1 This Policy will be updated, amended or revised from time to time to ensure its adequacy in implementation and enforcements.