1. Purpose
Bayarcash is committed to the highest standards of integrity, transparency, accountability, and ethical conduct in all its business dealings. This policy provides a safe and confidential channel for employees, management, business partners, and other stakeholders to raise concerns regarding misconduct, regulatory breaches, or unethical practices within Bayarcash.
The policy is designed to:
- Encourage stakeholders to report genuine concerns in good faith.
- Provide protection against retaliation for whistleblowers.
- Ensure all reports are investigated promptly, fairly, and independently.
- Support compliance with Bank Negara Malaysia (BNM) regulations, the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act (AMLA), and other applicable laws.
2. Scope
This policy applies to:
- All Bayarcash employees, managements, and directors.
- Contractors, agents, service providers, and third parties acting on behalf of Bayarcash.
- Third parties acting on behalf of Bayarcash, including partners, vendors, merchants, and service providers.
Matters that should be reported include, but are not limited to:
- Financial irregularities, fraud, or embezzlement.
- Breach of payment gateway regulatory requirements, AML/CFT obligations, or PCI DSS compliance.
- Bribery, corruption, or conflict of interest.
- Misuse of customer data or breach of confidentiality.
- Abuse of authority, harassment, or unethical conduct.
- Concealment or deliberate suppression of any wrongdoing.
3. Principles
Bayarcash is committed to protecting whistleblowers by ensuring confidentiality, preventing retaliation, and conducting fair investigations, fostering a safe environment for reporting concerns.
| Principle | Description |
|---|---|
| Confidentiality | All reports will be treated in strict confidence. Whistleblower identity will only be disclosed with consent or as required by law. |
| Good Faith Protection | Whistleblowers who report concerns honestly and in good faith will not suffer retaliation, even if the report is not substantiated. |
| Non-Retaliation | Bayarcash prohibits dismissal, demotion, suspension, threats, harassment, discrimination, or any form of retaliation against whistleblowers. |
| Fair Investigation | Allegations will be reviewed and investigated impartially, with findings reported to senior management and, where applicable, regulators. |
4. Reporting Channels
Whistleblowers may raise concerns through any of the following secure channels:
| Reporting Channel | Details |
|---|---|
| Dedicated Whistleblowing Email | compliance@bayarcash.com |
| Whistleblowing Hotline | [Insert phone number] |
| Direct Submission | To the Compliance & Risk Officer, HR Manager, or Board Audit & Risk Committee. |
| Anonymous Reporting | Allowed; however, providing contact details is encouraged for effective follow-up. |
5. Investigation Process
Bayarcash follows a structured and transparent process for handling whistleblowing reports to ensure accountability, fairness, and timely resolution of all concerns.
| Process Step | Description |
|---|---|
| Acknowledgement | Report will be acknowledged within 5 working days. |
| Preliminary Review | Compliance Officer will assess the report’s validity and scope. |
| Formal Investigation | Conducted by the Compliance & Risk Team, Audit Committee, or an independent appointed party. |
| Outcome & Action | Findings will be reported to senior management and/or Board Audit & Risk Committee. Corrective action, disciplinary measures, or regulatory reporting will be taken as required. |
| Feedback | Where possible and appropriate, whistleblowers will be updated on the outcome, subject to confidentiality. |
6. Protection & Support
- Whistleblowers will be shielded from retaliation under the Whistleblower Protection Act 2010 (Malaysia).
- Support may include HR assistance, legal protection, or referral to relevant authorities.
- Any retaliation will result in disciplinary action, including possible termination.
7. False or Malicious Reports
Deliberately false, malicious, or frivolous reports are considered misconduct and may result in disciplinary or legal action.
8. Review of Policy
This policy will be reviewed annually, or earlier if required by changes in BNM regulations, AMLA, or internal compliance needs.