Toyota Capital Malaysia Sdn. Bhd. ("TCAPM") operates a zero-tolerance approach to bribery and corruption and considers such activity to be unethical and contrary to good corporate governance.
TCAPM is committed to full compliance with all laws relating to anti-bribery and anti-corruption in Malaysia, particularly the Malaysia Anti-Corruption Commission Act 2009 (MACC Act 2009) together with the subsequent amendments to the MACC Act and all guidelines issued by Toyota Financial Services Corporation (TFSC) and relevant authorities pertaining to the same.
To uphold the above commitments:
- TCAPM must not offer, promise or give, directly or through a third party any money or other financial advantage or anything of value for the purpose of obtaining or retaining business or an advantage in the conduct of business for the company.
- TCAPM has set out Anti Bribery Policy that stipulates its associates' responsibilities, and other stakeholders including but not limited to any agents, or third parties, to observe and uphold its position on bribery and corruption
- TCAPM has established an independent compliance function to oversee and implement anti-bribery programs, control and provide information and guidance on associates' responsibilities, and other stakeholders including but not limited to any agents, or third parties, to observe and uphold TCAPM's commitment to bribery and corruption. On annual basis, the management shall review the Anti Bribery Policy to ensure its continuing suitability and its ongoing effectiveness.
- TCAPM shall take appropriate disciplinary action as appropriate against its associated that were found to be non-compliant with the Anti Bribery Policy in accordance with applicable laws and the TCAPM's policies & procedures.
TCAPM has established Whistle Blowing Policy as part of the management's continuous effort and commitment to promote and implement good corporate governance practices throughout the company.
TCAPM through its Whistle Blowing policy encourages its associates or any other persons including the general public to raise concerns on any wrongdoings relating to mismanagement or abuse of authority, corruption, fraud, and financial malpractices or any breach of laws and regulations of its associates, through TCAPM's whistleblowing channel on a confidential basis.
What to Disclose
Any concerns raised through whistleblowing must be genuine concerns about any improper conduct occurring within TCAPM that may adversely impact TCAPM including but not limited to:
- Corruption or corrupt practice;
- Mismanagement and abuse of the Company's fund, assets or confidential information;
- Financial malpractices;
- Conflict of Interest;
- Contravention of laws and regulations such as an act or omission which creates a substantial and specific danger to the lives, health or safety of TCAPM's employees or the public or the environment;
- Criminal offence;
- Knowingly directing or advising a person to commit any of the above wrongdoings
Whistleblowers are advised to make their disclosures in writing and to provide sufficient details which include but are not limited to the following:
- the type or description of the misconduct;
- the name of individuals who have committed or are involved in the action; full details of the concern raised, including the 'what', 'when' and 'where' in relation to the misconduct; and the relevant supporting documents or evidence, if any.
Subject to the paragraph below and in accordance with the whistleblower Protection Act 2010, the whistleblower will be protected from retaliation, adverse employment action or legal action and where feasible, from the disclosure of the identity, provided always that the report made is in good faith
Exclusion of Protection
Under Section 11 (1) (a) to (f) of the Whistleblower Protection Act 2010, the Whistle blower's protection shall be revoked if a person is found to have:
- participates in wrongdoing;
- made a disclosure in a dishonest way, frivolous mischievous or malicious complaints;
- made a material statement that he knew or believed to be false or did not believe to be true;
- made a disclosure with a motive to avoid dismissal or other disciplinary action;
- violated the Whistleblower Protection Act 2010 in the course of making the disclosure or providing further information;
- made a disclosure of improper conduct which principally involves questioning the merits of the government policy, including the policy of a public body.
Note: All documents obtained pertaining to the disclosures shall be treated as "Confidential".
All disclosures in relation to this policy shall be made to the following designated recipient:
- E-mail to firstname.lastname@example.org
- Send a letter to:
Chief Compliance Officer
Toyota Capital Services Sdn Bhd
Level 20, Plaza IBM,
First Avenue, Bandar Utama,
47800 Petaling Jaya,
Selangor Darul Ehsan
(Whistleblower shall indicate the title of the e-mail/envelope as: STRICTLY PRIVATE & CONFIDENTIAL)