Delivering Sustainable Value For Our Stakeholders Delivering Sustainable Value For Our Stakeholders Press Metal Aluminium Holdings Berhad 102 103 Integrated Annual Report 2023 Upholding Good Governance and Economic Resilience Upon submission of the Whistle-Blower Form, a thorough investigation will be conducted by an assigned investigator, typically chosen from our competent internal auditors, unless specified otherwise by the AC Chairman. The investigator’s impartiality and independence are essential for upholding fairness, credibility and legal standards throughout the investigative process. Furthermore, the AC updates the Board annually on whistle-blowing matters. Stakeholders who use these whistle-blowing channels can report without fear of retribution, as the policy protects against retaliation, threats or intimidation as per Malaysia’s Whistleblowers Protection Act 2010. In addition, we review the WhistleBlowing Policy every five (5) years to ensure its relevance and alignment with changing regulatory standards. Anti-Bribery & Anti-Corruption Policy We maintain a zero-tolerance stance against bribery and corruption. Our stance is written in our ABAC Policy which also defines potential activities which constitute bribery and corruption, such as commissions, unofficial payments, gifts, political contributions, gratifications and charity. In addition, our ABAC Policy stipulates the requirements for risk assessments, training programmes and effective reporting mechanisms to manage potential bribery or corruption risks. The AC assists the Board in overseeing the implementation of and compliance to the ABAC Policy, by establishing robust oversight on financial reporting, internal and external audit processes, related party transactions, conflicts of interest and risk management matters. To that end, our Board regularly reviews and updates the ABAC Policy and accompanying procedures to align with regulatory requirements, including Section 17A(1) of the Malaysia Anti-Corruption Commission (Amendment) Act 2018. Supported by an in-house Internal Audit Department, the AC receives assurance regarding the adequacy and integrity of our risk, governance and internal control systems through the risk-based audit approach outlined in our annual audit plan, covering major subsidiaries of the Group. This internal audit function assists AC in oversight of ethical standards and regulatory requirements. At the entity level, the implementation of the ABAC Policy falls under the responsibility of the respective Human Resource (“HR”) departments. All personnel, from directors to employees, are reminded about the ABAC Policy through various channels, such as corporate website, induction programmes, training sessions and briefings. While directors, management and employees are to adhere to the principles outlined in the ABAC Policy, all personnel are required to sign a declaration of compliance to declare their commitment to upholding the policy. Enhancing Anti-Corruption Measures Within Our Supply Chain To ensure robust internal control of adherence, we have established a multi-level approval process. Financial transactions, for example, undergo a three (3)-tier approval involving the performer, checker and approver. This approach serves as a checkand-balance system, ensuring integrity and transparency in all commercial decisions and providing us with the ability to promptly identify and address potential corruption risks. We are dedicated to fortifying our internal controls and procedures through promoting the identification and monitoring of corruption risks within our supply chain. Supporting this, our ABAC Policy extends to third-party providers as outlined in the SCoC, and adherence to the policy is expected across all suppliers, consultants, contractors and service providers. 1 Verbally to the Chairman of the AC, followed by submission of our Whistle-Blower Form; 2 Emailing a completed Whistle-Blower Form to whistleblowing@pressmetal.com; or 3 Sending a completed Whistle-Blower Form to the Chairman of the AC via mail. Sponsorship, Donations and Political Contributions As an apolitical publicly listed company, we maintain a stance of impartiality and refrain from endorsing or favouring any particular political party’s agenda. Nonetheless, we actively support Malaysian government initiatives aimed at driving progress and innovation, such as the Fourth Industrial Revolution transformation and the National Economic Recovery Plan. By aligning with these initiatives, we contribute to the broader national goals of economic growth, technological advancement and sustainable development. Any proposals for donations or sponsorships, such as those for humanitarian causes, healthcare, education and community development, should not influence any business decisions or serve as compensation for improper payments or bribery. Approval by two (2) Executive Directors is required for all sponsorships and donations, regardless of the amount, and contributions must be accurately recorded in our financial records, comply with applicable laws and be capable of public disclosure. Mergers and Acquisitions Policy Our Mergers and Acquisitions Policy provides clear protocols and guidelines for engaging potential investee companies. To ensure that our partnerships are founded on shared values and objectives, our assessment includes adherence to relevant laws and regulations as well as assessment of financial and non-financial risks such as bribery, corruption and other financial offences. Furthermore, potential investee companies must undergo due diligence, which includes a self-assessment questionnaires on ESG that assesses their sustainability maturity, along with background checks, document verification processes and bribery risk assessments. Where necessary, contractual clauses are included to permit termination of contracts with business partners in instances such as bribery or corruption is identified and not mitigated. Closure, Decommissioning & Divestment Plan Our Closure, Decommissioning and Divestment Plan serves as a framework for the decommissioning of redundant facilities and infrastructure. Aligned with our commitment to responsible business practices, the plan provides guidelines for restoration to usable land, and also outlines procedures for communicating with government agencies and local communities during the closure or decommissioning process. Our closure and decommissioning policies apply to operations where we hold a controlling position, while our divestment policies do not apply to investments where we lack management control or decision-making authority. Rotation of Audit Firm and Audit Partner We have adopted a Statutory Auditors and Statutory Audit and Non-Audit Services Framework (“Statutory Auditor Framework”) which stipulates: 1. Regular rotation of the lead audit partners and consideration of the necessity of a regular rotation of the audit firm; and 2. Conduct of AC to assess the performance, suitability and independence of our external auditors. We have also established a requirement for the lead partner and quality control partner to rotate every seven (7) years and observe a cooling-off period of five (5) years, aligning with current professional standards set by the Malaysian Institute of Accountants. OUR VALUE CREATION We have proactively taken measures to ensure adherence to the latest amendments announced by Bursa Malaysia to the MMLR. These revisions, designed to uphold the ongoing suitability of the MMLR, aim to improve various aspects of the MMLR to tackle market concerns and maintain clarity, relevance and compliance with current standards. In August 2023, our Board deliberated and approved the Conflict of Interest Policy to address these new requirements. This policy applies to all directors, key senior management and key operating management of the Group, addressing circumstances that constitute or give rise to conflicts of interest, such as being an interested party in a proposed project or contract. In instances where a conflict of interest arises, it is now mandatory to promptly disclose the nature and extent of the conflict. Whistle-Blowing Policy Our Whistle-Blowing Policy establishes a formal, anonymous and confidential channel for internal and external stakeholders to report in good faith of any misconduct or illegal acts, such as violations of the CoC and CoE, corruption, bribery and threats to health and safety. Whistle-blowers can also report allegations or suspected improper activities that contravene our standards of integrity and fairness within the business environment, as well as incidents related to human rights violations and malpractice. Whistle-blowing reports can be made via three (3) channels: Upholding Good Governance and Economic Resilience
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