TCM259

RSGC Whistle Blowing Policy

The Royal Selangor Golf Club (“RSGC”) strives to conduct its business and operations with integrity, competence and professionalism while achieving the highest level of effectiveness and excellence. As the premier Club of Malaysia, we expect all our stakeholders to behave in a manner which enables us to achieve this and it is important that RSGC is alerted of any actual or potential improper conduct which compromises these aspirations.

 

What is Whistleblowing about? 

RSGC’s Whistleblowing Policy (“WBP”) provides an avenue for employees, members, vendors/contractors and other stakeholders to communicate improper conduct such as theft, fraud, sexual harassment, bribery, abuse of power, conflict of interest and non-compliance with established policies and procedures. This list is not exhaustive. It also includes conduct which does not comply with RSGC’s Code of Conduct and Anti-Bribery and Anti-Corruption Policy and all other laws of Malaysia.

 

How do you make a disclosure? 

All reports of improper conduct are to be directed to the President and the Chairman of the Disciplinary Sub-Committee at

whistleblowing.pres@rsgc.com.my ; and whistleblowing.dsc@rsgc.com.my

 

Your report should contain:-

  1. A brief description of the misconduct;
  2. The date and location of the incidence;
  3. The identity of the wrongdoer;
  4. Particulars of witnesses, if any;
  5. Supporting evidence and/or documents;
  6. Other details which may be useful to us to review the report and to help us decide on the action to be

Where possible, the whistleblower is encouraged to disclose his/her following details to enable the relevant parties conducting the investigation to contact the Whistleblower for further information:

  1. Name; and
  2. Contact details – email address and/or telephone

All reports received will be expeditiously reviewed and investigated by the Disciplinary Sub- Committee and the results of such investigation, including the validity of the allegations and accompanying recommendations, shall be tabled to The Committee for their consideration.

 

Duty of the WhistleBlower

In making the report, the Whistleblower must:-

  1. act in good faith;
  2. have reasonable grounds and a reasonable basis for doing so, and
  3. not be acting for his own personal If the case involves the complainant’s personal interests, the interest should be disclosed at the outset.

 

Confidentiality 

RSGC will ensure that all disclosed information, including the identity of the whistleblower, shall be treated with strict confidentiality. All personnel, directly or indirectly working relative to a whistleblowing case, shall strictly protect the identity of the whistleblower and witnesses from unauthorized disclosure before, during and after an investigation.

RSGC is also committed to protect the whistleblower from all acts of harassment, retaliation, victimization and recrimination arising from making the disclosure in good faith.

There may be certain circumstances where the identity of the whistleblower may need to be revealed on a need-to-know basis (e.g. requirement to testify in court). If such a situation arises, RSGC will contact the whistleblower for his consent first before proceeding with the case.

The protection will be removed if it is found that the whistleblower was also involved in the improper conduct, or if the whistleblower is found to have made the disclosures in bad faith.

 

Anonymous reports

Anonymous reports may be investigated after having considered the following:

  • Seriousness of the allegations contained in the report;
  • Credibility of the allegations; and
  • Whether it is likely that RSGC is able to confirm the allegations with credible

 

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