Whistleblowing Policy

    1. Purpose and Commitment

SPCI HELM Group is committed to conducting business with integrity, transparency, and accountability. This Whistleblowing Policy provides a mechanism for employees, business associates, and third parties to raise genuine concerns regarding any suspected misconduct, illegal conduct, or malpractice, without fear of victimisation, retaliation, or discriminatory treatment.


2. Scope

This Policy applies to all employees, directors, consultants, contractors, suppliers, agents, and any third parties dealing with SPCI HELM.

 

3. Definition of Improper Conduct

Improper conduct includes, but is not limited to:

  • Fraud & Corruption: fraud, embezzlement, misappropriation of assets, money laundering, procurement fraud, suspicious dealings, profiteering based on insider knowledge.
  • Abuse of Power: abuse of authority, impersonation of officials, misuse of company information.
  • Breach of Trust: breach of confidentiality, non-compliance with laws, regulations, or company policies, subversion of audit processes, negligence.
  • Criminal Offences: criminal breach of trust, forgery, falsification of documents, workers’ compensation fraud, any other criminal act.
  • Other Wrongdoing: any act detrimental to the interest of the Company or stakeholders.

4. Reporting Channels

Reports may be submitted through the following channels:

  1. Email: legal@spci-helm.com
  2. In Person/Mail: Legal Department
  3. Address: A-3A-07 & A-3A-08, Kompleks Perindustrian Emhub Persiaran Surian, Seksyen 3 Taman Sains Selangor, Kota Damansara, 47810 Petaling Jaya, Selangor
  4. Alternative Escalation: If the concern involves the Legal Department, reports may be made directly to the Directors.

Reports may be made anonymously. However, anonymity may limit the Company’s ability to investigate. Anonymous reports will be assessed at the discretion of the Whistleblowing Committee.


For mailed in reports, they must be placed in a sealed envelope labelled “Strictly Confidential. To be opened by Addressee only.” on the top left-hand corner.

 

5. Information Required

To assist investigation, reports should include (where possible):

  • Full name, NRIC and contact details.
  • Type of activity or conduct.
  • Details of personnel involved.
  • Place, date, and time of incident(s).
  • Supporting documents, records, or evidence.

6. Confidentiality and Protection

  • All disclosures will be treated as confidential.
  • The identity of whistleblowers will be protected to the fullest extent possible.
  • Whistleblowers acting in good faith are protected under the Whistleblower Protection Act 2010 (Act 711).
  • Any retaliation against a whistleblower is strictly prohibited and will result in disciplinary action.
  • Protection does not extend to whistleblowers who knowingly submit false, malicious, or frivolous reports.

7. Investigation Process

  1. Receipt & Acknowledgement
    Reports will be acknowledged within 10 calendar days, unless submitted anonymously.
  2. Initial Assessment
    The Legal Department will conduct an initial verification and assessment on the report received and present the initial findings to the Whistleblowing Committee.
  3. Whistleblowing Committee
    A Whistleblowing Committee, independent of the matter, will evaluate initial assessment and assign an investigation party or investigation team to conduct detailed investigation. External experts may be engaged where necessary. The composition of the Whistleblowing Committee shall be randomised and will vary with each report to ensure impartiality and justice.
  4. Investigation
    Investigation party or investigation team will perform thorough investigation of the report and present their findings to the Whistleblowing Committee.
  5. Outcome & Actions
    Findings will be reviewed by the Whistleblowing Committee. Appropriate action will be taken, including disciplinary measures, termination of contracts, or implementation of new controls.
  6. Reporting
    The Governance Committee will report investigation outcomes to the Management or Board of Directors. Investigations will generally be completed within a reasonable timeframe, subject to complexity of the case.

8. Record Keeping

The Company will maintain records of all whistleblowing reports, investigations, and outcomes for a minimum of seven (7) years.

 

9. Policy Review

This Policy will be reviewed annually and may be amended from time to time to ensure effectiveness and compliance with applicable laws and regulations.