1. | INTRODUCTION |
The Board of Directors (“Board”) of Engtex Group Berhad (“Company) is mindful of the everpresent and growing threats of fraud against the Company and its subsidiaries (“Group”), and the Board adopts a zero-tolerance attitude towards frauds committed against the Group. This Policy forms part of the larger Corporate Governance setting of the Group which entails other policies such as the Whistle-Blowing Policy, Anti Bribery & Corruption Policy, Code of Ethics & Conducts etc., which supplement the applications of this Policy. |
2. | OBJECTIVES | |
This Policy aims to achieve the following: | ||
2.1 |
Setting tone – affirms the Board’s stance against any fraud committed against the Group and create awareness among the employees and business associates (including agents, representatives, clients/customers, vendors, shareholders etc.). | |
2.2 | Framework – establishes or provides a framework for the Group and its employees to deal with actual and suspected fraud incidents in a consistent manner. | |
2.2 | Procedures – outlines the procedures for fraud response, investigation, monitoring and reporting. | |
2.2 | Responsibilities – assigns responsibilities for fraud detection, investigation and development of internal controls against frauds. |
3. | SCOPE | ||
3.1 | This Policy shall apply to all level of personnel of the Group and its business associates. | ||
3.2 | Actions constituting fraud include but not limited to: | ||
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4. RESPONSIBILITIES
Body/Function/Individuals | Roles and Responsibilities |
Board of Directors |
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Audit Committee / Risk Management Committee | Periodic risk assessment on fraud risk of the Group. |
Group Managing Director /Executive Management | Primarily responsible for the Group-wide implementation, review and monitor internal control system for the prevention and detection of frauds. Lead by example. |
Subsidiaries’ Directors and Senior Management |
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Other employees | Day-to-day prevention, detection and reporting of frauds. |
Internal Auditors Function |
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Human Resources & Administration Function |
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5. | POLICY |
The Board of Directors is committed to preventing and addressing all significant acts of fraud against the Group. All employees shall perform their duties with honesty, integrity and in an ethical manner. All actual or suspected frauds shall be reported and handled according to the procedures laid down in this Policy, or according to the Group’s Whistle-Blowing Policy which is available at the Group’s corporate website. |
6. | PROCEDURES | ||||||||||||||||
6.1 Making a Report | |||||||||||||||||
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Where possible, the report should cover the following: - | |||||||||||||||||
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Anonymous reporting may be accepted provided that the reporting is made in good faith and is supported by credible and actionable information and evidence.
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6.2 Investigation | |||||||||||||||||
The Senior InThe Senior Independent Director or the Audit Committee Chairman, may instruct the Group Internal Audit Department, or other senior management personnel (e.g. the Group Human Resources & Administration Manager) who are not implicated in the fraud incident and are likely able to maintain impartiality, or an external independent party to carry out an investigation on the reported incident. During the period of investigation, the accused wrongdoer may be temporary reassigned to other department/function or asked to take leaves, pending the outcome of the investigation.dependent Director or the Audit Committee Chairman, may instruct the Group Internal Audit Department, or other senior management personnel (e.g. the Group Human Resources & Administration Manager) who are not implicated in the fraud incident and are likely able to maintain impartiality, or an external independent party to carry out an investigation on the reported incident. During the period of investigation, the accused wrongdoer may be temporary reassigned to other department/function or asked to take leaves, pending the outcome of the investigation.
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6.3 Post-investigation Actions | |||||||||||||||||
Should the investigation reveals that fraud had been committed and parties involved are identified, a recommendation shall be forwarded to the Group Human Resources & Administration Department for appropriate actions to be taken against the wrongdoer, including but not limited to employment termination, reporting the case to the police or other relevant authorities, and/or recover financial losses or obtaining compensation. |
7. | CONFIDENTIALITY |
Information gathered and investigation results will not be disclosed and discussed with anyone other than those with a legitimate need to know. This is to avoid unnecessary damage to the reputation of the accused wrongdoers who may be found innocent of wrongdoings by the investigation. |
8. | FRAUD REGISTER |
A Group Fraud Register shall be maintained by the Group Internal Audit Department, which will be used as a basis for reporting incidents of suspected or actual fraud and outcomes of investigation undertaken into suspected fraud, including the value of any loss to the Company |
9. | ADMINISTRATION |
The Audit Committee is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed at least once every 2 years. |