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1.1 Whistleblowing is a form of disclosure involving a person, i.e. the whistleblower, who raises serious concerns about the risk of Improper Conduct or to report unethical or unlawful behavior and practices by the Personnel of Sun Life Malaysia Assurance Berhad and Sun Life Malaysia Takaful Berhad (hereinafter collectively referred to as the “Company”) and/or Third Party engaging and having a business relationship with the Company. Whistleblowing at the earliest opportunity may significantly prevent and/or reduce harm arising from Improper Conduct.
1.2 The purpose of the Guidelines is to outline a formal and confidential way in which the Company’s Personnel and Third Party can express their concerns on any form of Improper Conduct at an early stage and through appropriate channels.
1.3 The Company is committed to ensure that its Personnel and Third Party are able to raise genuine concerns in relation to a breach of a legal obligation, fiduciary duty, and miscarriage of justice, bribery and corruption at the earliest opportunity without being subject to victimization, harassment or discriminatory treatment and to have such concerns properly addressed and investigated.
1.4 The Guidelines shall complement and is to be read in conjunction with all of the Company’s prevailing policies and procedures including policies relating to the prevention of corruption and bribery.
2.1 The Guidelines shall apply to the Company, its Personnel and the Third Party engaging and having a business relationship with the Company.
2.2 Complaint or report of an Improper Conduct against the Company or any of its Personnel can be made by lodging a complaint or report through the appropriate channel set under item 10 of the Guidelines.
2.3 All Personnel and Third Party are expected to read, understand and comply with the requirements set in the Guidelines.
3.1 The following definitions shall apply in the Guidelines :
"BUCO" means Business Unit Compliance Officer of the Company
"Confidential Information" means any information that is confidential in nature or sensitive and/or not generally available to the public and in the Guidelines including but not limited to:
5.REQUIREMENT OF GOOD FAITH
6.PROTECTION AGAINST DETRIMENTAL ACTION
7.PROTECTION OF CONFIDENTIAL INFORMATION
8.WHEN PROTECTION MAY NOT BE GIVEN
9.LODGING AN IMPROPER CONDUCT REPORT
10.HOW TO LODGE AN IMPROPER CONDUCT REPORT
WHISTLEBLOWER PROTECTION ACT 2010
The Company reserves the right to amend, modify or update the Guidelines periodically and at any time by updating and publishing the effective date of the release of the new version hereof through an internal circulation to the Personnel or by making it available in the Company’s corporate website.
15. QUESTIONS AND FURTHER INFORMATION