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SUSTAINABILITY JOURNEY HOW WE ARE GOVERNED FINANCIAL STATEMENTS ADDITIONAL INFORMATION 261

Establishment of MSM Whistleblowing Channel (System) MSM Code of Business Conduct and Ethics (CoBCE)
& Committee Policy for Employees

On 25 May 2021, the Board has approved the establishment On 25 November 2021, the Board has approved the revision
of Whistleblowing Channel (System) & Committee in MSM of MSM CoBCE Policy. The MSM CoBCE Policy guides
Malaysia Holdings Berhad and its group of Companies our employees in embracing the Group’s values and in
for implementation. Previously, MSM adopted FGV complying with applicable law and regulations through
whistleblowing reporting channel & committee, being honest, transparent and ethical business practices. The MSM
managed by FGV Whistleblowing Secretariat. CoBCE Policy covers areas such as compliance, integrity,
conduct in the workplace, business conduct, protection of
The channel which allows reporting of any allegations of the Group’s assets, confidentiality and conflict of interest.
misconduct within the Group is also a preventive measure
against unethical conduct. The channel thereby supports MSM Authority and Responsibility
to maintain the highest standard of ethical and legal conducted
within the Group. Organisation Structure

MSM External Gift Entertainment and Hospitality Policy The Group has a comprehensive organisational structure which
organises its business operations. The organisational structure
MSM Group recognises that the giving and accepting of gifts, provides clear lines of reporting, authority and segregation
entertainment and hospitality can be part of building normal of duties, which promotes ownership, accountability, and
business relationships. The aim of the Policy is to ensure that delegated authority.
the highest standards of integrity are maintained and that it
can never be suggested that there was an improper motive Limits of Authority (LOA)
behind the offer or acceptance of the gift, entertainment and A documented Limits of Authority (LOA) with clear lines of
hospitality will unduly influence the recipient. The policy was accountability and responsibility serves as a tool of reference
approved by the Board.
to identify the appropriate approving authority at various levels
MSM Referral Policy of management including matters that require the Board’s
approval. The new LOA of MSM Group was approved and
On 25 August 2021, the Board has approved the establishment subsequently implemented effective 23 November 2020.
rd
of MSM Referral Policy. The purpose of this policy is to
establish the rules and principles for referrals on criminal cases Job Description
including but not limited to fraud, bribery and abuse of power Each role in the organisation structure is supported by clear
to Enforcement Agencies.
description of job responsibilities which are linked to the vision
This policy provides guided parameters to ensure that referral and goals of the Group. A well developed and effective job
protocols are adhered to in relation to when the information description has been designed for clarity of responsibilities
is received, the results of investigation and any other matters and relationship between functions which will enhance
related to it. collaboration across the Group moving towards operational
efficiency besides supporting the succession planning.
MSM Conflict of Interest Policy It can retain and motivate the best talents by ensuring that
employee’s engagement and helps drive high performance
On 25 August 2021, the Board has approved the establishment culture.
of MSM Conflict of Interest Policy. All employees and third
parties of MSM Group shall act, at all times, in the best interest
of MSM Group and not based upon their personal interest.
Employees must not put themselves in a position where they
are involved in an activity for personal gain, to themselves,
their ‘relative’, ‘associate’ or third parties, or any activity that
conflicts with MSM Group’s interest.