Whistleblowing Policy

Whistleblowing Policy

(Governance Framework of the IPP Entities)

1. Purpose

This Whistleblowing Policy applies to the following entities (collectively referred to as the “IPP Entities”):

  • IPP Global Wealth Sdn Bhd (IPPGW)
  • IPP Financial Advisers Sdn Bhd (IPPFA)
  • IPP Wealth Managers Ltd (IPPWM)

Each entity is a separate legal entity operating within its respective regulatory framework.

The IPP Entities are committed to maintaining the highest standards of integrity, transparency, and ethical conduct. This Policy establishes a safe and confidential mechanism for reporting suspected misconduct, breaches of law, regulatory violations, or breaches of internal policies, including the Anti-Bribery & Anti-Corruption Policy.

The objective is to encourage responsible reporting in good faith, while ensuring fair treatment and protection from retaliation.

2. Scope of Application

This Policy applies to disclosures relating to the conduct of:

  • Directors and officers
  • Employees (permanent, contract, temporary)
  • Representatives, agents, introducers, and associates
  • Consultants, contractors, and service providers
  • Any third party acting for or on behalf of the IPP Entities

Reports may be made by employees, business partners, clients, vendors, or any external party with reasonable grounds to believe misconduct has occurred or may occur.

3. Reportable Matters

Disclosures may relate to actual or suspected improper conduct, including but not limited to:

  • Bribery, corruption, facilitation payments, or kickbacks
  • Breaches of the Anti-Bribery & Anti-Corruption Policy
  • Fraud, theft, embezzlement, or dishonesty
  • Misuse or misappropriation of funds or assets
  • Financial misconduct or improper accounting
  • Serious conflicts of interest
  • Abuse of authority
  • Breaches of legal or regulatory obligations
  • Gross mismanagement or conduct damaging to reputation
  • Deliberate concealment of any of the above

4. Good Faith Reporting

4.1 Disclosures must be made in good faith, based on reasonable belief.

4.2 A whistleblower is not required to prove the allegation. It is sufficient that the concern is honestly raised.

4.3 Knowingly false, malicious, or frivolous allegations may result in disciplinary action.

5. Protection Against Retaliation

The IPP Entities prohibit retaliation against any individual who makes a report in good faith.

Protection includes safeguards against:

  • Dismissal
  • Demotion
  • Harassment
  • Discrimination
  • Any other detrimental action

Protection applies regardless of whether the concern is ultimately substantiated.

However, this Policy does not shield individuals who are found to have participated in misconduct.

6. Confidentiality

All disclosures will be handled confidentially to the extent reasonably practicable.

Information may only be disclosed where:

  • Required by law or regulatory authorities
  • Necessary for investigation or legal proceedings
  • Required for professional advice (e.g., legal or audit)

Where disclosure of identity becomes necessary, reasonable efforts will be made to inform the whistleblower in advance.

7. Anonymous Reports

Anonymous disclosures are accepted and will be assessed objectively.

However, anonymity may limit the ability to investigate fully or provide feedback.

8. Reporting Channels

Disclosures should preferably be made in writing to the designated governance contact:

Email: governance@ippgw.com
(Or specify separate compliance emails for each entity if preferred)

Reports should include, where possible:

  • Description of the concern
  • Relevant dates and persons involved
  • Supporting documentation (if available)

Where appropriate, reports may be escalated to senior management, the Board, or relevant regulatory authorities.

9. Investigation & Oversight

All reports will be assessed promptly and independently.

Depending on the nature and severity of the matter, investigations may involve:

  • Internal management or compliance personnel
  • Internal or external auditors
  • Independent legal or forensic professionals
  • Referral to regulatory or enforcement authorities

Findings will be escalated to the appropriate level of governance oversight.

10. Relationship with Other Policies

This Policy operates in conjunction with:

  • Anti-Bribery & Anti-Corruption Policy
  • Code of Conduct
  • Regulatory Compliance Policies

Reports relating to bribery or corruption will be managed in accordance with the Anti-Bribery & Anti-Corruption framework.

11. Governance Oversight

The respective Boards of the IPP Entities retain ultimate oversight of this Policy.

This Policy will be reviewed periodically to ensure alignment with evolving legal, regulatory, and governance standards.