MARC Group and its subsidiaries (hereinafter referred to as “MARC”) are committed to the highest level of integrity from its employees in all their dealings. Any illegal, improper, unethical conduct or questionable practices (collectively referred as “improper conduct”) by MARC employees will be treated seriously and dealt with swiftly in a fair but firm manner. 

MARC has implemented a Whistleblowing Policy to provide a structured reporting channel and guidance to all employees and external parties to report instances of unethical behaviour, fraud, misconduct, bribery or violation of MARC’s Code of Business Ethics without fear of victimisation, discrimination and/or being disadvantaged.

Parties can report a Whistleblowing complaint if they are aware of any wrongdoings, including, but not limited to the following:

• Fraud;
• misappropriation of assets;
• sexual harassment;
• criminal breach of trust;
• illicit and corrupt practices;
• questionable or improper accounting;
• Profiteering as a result of insider knowledge
• misuse of confidential information
• acts or omissions which are deemed to be against the interest of the Company, laws, regulations, or public policies;
• breaches of Group Policies and Code of Ethics and Business Conduct or
• giving false or misleading information (including suppression of any material facts or information);

Confidentiality

MARC will make every effort to keep your identity confidential. In order not to jeopardise the investigation, you should also keep the fact that you have filed a report, the nature of your concern and the identity of those involved confidential.

For investigation purposes (where necessary), the consent of the Whistleblower is to be sought to disclose their identity including disclosure to the Law Enforcement Agency (LEA).

Protection to the Whistleblower 

Protection of confidentiality of the identity of the accorded to employees and members of the public whistleblower, to the extent practicable, will be provided that the disclosure is made in good faith and without malicious intent or for personal gain. However, in the event it is discovered that the whistleblower has made a disclosure in bad faith and/or with malicious intent and/or for ulterior/improper motive or for any personal gain, the protection can be revoked. Employees who whistleblowing are given the additional protection that he or she will not be subject to detrimental or retaliatory actions at the workplace. 

The principles on confidentiality granted to the whistleblower will also apply equally to the employee under investigation. MARC has an independent investigation process to investigate all whistleblowing reports based on investigation protocol which accords with the principles of fairness, independence and propriety. Where the improper conduct involves a suspected criminal offence, MARC will report the matter to the relevant authority for their further action and unless compelled by law, will strictly safeguard the identity of the whistleblower in accordance with the Whistleblowers Protection Act 2010 (Act 711).