whistle blowing Policy

1.Purpose

All employees from AYASOMPO Insurance Company, both from Head quarter and from branches and branch offices form regional, can report concerning malpractice and wrongdoing within the workplace. Also, this policy is defined to protect the reporting staffs from the worry of retaliating or making trouble with wicked mind.

2. Policy

As AYASOMPO Insurance Company defined the standards higher in honest and transparency for taking responsibilities and duties, starting with each employee, the entire company are urged to follow defined standards and report such issues for better results. Revealing honestly, by believing as staying in line with the standard of company and without being afraid of affecting personality, insecurity of position and department, being fired. The reported case can be assumed that it was done honestly If the reported employees can explain that malpractice or the related issue was done with innocent.

3. Responsible person and level of authorities

3.1 First level Officer for Whistle Blowing Policy
Daw Wai Wai Lwin — Deputy Manager (Recruitment and Selection, Compensation and Benefits)
Daw Khin Phone Oo — Deputy Manager (Learning and Development, Employee Relations)
Employees can contact concerned officer when they want to reveal and discuss. In this case, they can easily fill the reach HR Form from HR Application and make a contact. The issues will be negotiated, solved, and reported by concerned officer.

3.2 Second level Officer for Whistle Blowing Policy 
Daw Wai Zin Maung — Divisional Head Support Division
U Htet Wai Min — Head of HR Department
are responsible to implement this whistle blowing policy. They are contact persons to reveal and inform. The received information and financial documents reported from audit will be accumulated and carried out. The disclaimers, the procedures of the investigators or the results of the investigations with the progress of taking actions are accumulated systematically in orders.

3.3 Third level Officer for Whistle Blowing Policy
U Myo Min Thu — Chief Executive Officer (AYA SOMPO Insurance)
has responsible to implement and amend the policy in keeping with the times. Also, be a contact person if the employees want to submit inquiry.

4. Scope 

This policy is applied to contract employees, Insurance specialist, and all the employees working under the AYASOMPO premises from Head Quarters and other branches.

5. Freedom of discussion policy and disciplinary actions 

This Policy is intended for the following important issues.
i. Financial misuse, Fraud, and malpractice.
ii. Expending the budget without permission.
iii. Corruption
iv. Conducting cases that are unconstitutional.
v. Misuse of authority and power of the position and department for the business or using for the personal benefits.
vi. Non-compliance as the regulator of the policy (e.g. move the property of the company without special permission)|
vii. Collusion, omission, concealment of the information concerning the cases described in above with intention.

6. Limitation of Whistle Blowing Policy

1. Discrimination between employees (e.g. Skin Tone, Religion, Race, Disabilities, Gender (Male/Female), Family Condition etc.)
2. Cases that can go with Grievance Handling Form
3. Complaints from customers about company’s services

7. Procedures 

The following stages will be conducted in whistle blowing policy.

7.1 First stage procedures
For employees directly contact and raise concerns to their respective superiors or to the authorized person about wrongdoings, malpractice, or illegal practices within the Company which they have become aware of. For the concerns, the employees can use “Reach HR” from HR Application for the convenience. Appointed Whistle Blowing Officers —

NameContact NumbersE-mail
Level-1 Authorized Persons  
Daw Wai Wai Lwin09-421 107 612waiwail@ayasompo.com
Daw Khin Phone Oo09-965409666khinpo@ayasompo.com
Level-2 Authorized Persons  
Daw Wai Zin Maung09- 550 0289waizm@ayasompo.com
U Htet Wai Min09-501 0614htetwaim@ayasompo.com

If the employee feels unable to raise the matter with his/her direct supervisors or appointed whistle blowing officers for any reason, or are not satisfied with the outcomes of initial investigation, he/she can raise the matter up with the CEO, either via Email or personally.

7.2 Second stage procedures
It’s best that the employee could provide them with as much information as possible, including any relevant names, dates and places and so on. The employee will have to show them that there are good reasons for your concern. The earlier the employee raise the concern, the easier it will probably be able to take effective action.


7.3 Third stage procedures

According to the statements mentioned in this policy, disclaimers from employees have to investigate and take action upon by CEO or authorized person as per below procedures; –
i. The disclaimer cases must take over with proper care and documented. The disclaimer cases must review and assess thoroughly.
iii. Authorized person may need the support and suggestion from Legal Unit if the cases are complication and relevant with government laws and regulations.
iv. The disclaimer cases must investigate, handle and solve properly without any delays.
v. The root cause of occurred cases must identify and inform.
vi. Non-discrimination policy must comply at all cause when handling cases.
vii. Take legal cover and action, If the disclaimer cases which involve legal and crime issues.

Authorized person can set up a meeting with the disclaimer employees during investigation period and number of meetings must depend upon the nature of cases and disclaimer employees must participate in the progress with their own will. The meeting location will be at AYA SOMPO Head Office and may change upon requirements. (The disclaimer employees and authorized person can bring an accompany if it is required.) Authorized person must keep confidential to the name and identity of declaimed employees unless only required for the legal and compliance matter.

7.4 Fourth stage procedures 
The whistle blowing officers from AYA SOMPO Insurance must maintain records of cases comprehensively according this policy. Records must include the outcomes investigation, decisions and improvement. (The whistle blowing officers must carefully control the forms which included the confidential of the complainant’s identity.) 

7.5 Fifth stage procedures
The whistle blowing must report the cases, investigation process and the results of each investigation at the Management Meeting for the improvement of process and action plans. 

8. Misconduct of Human Resource Department 

For the unfairness, misconduct, malpractice, or illegal practices from members of Human Resource Department, the employees can report or disclaim the incident through Workplace Coordinating Committee (WCC). The Workplace Coordinating Committee (WCC) will investigate as necessary and will only be reported to CEO. The Workplace Coordinating Committee (WCC) must follow the procedures from section 7.4 and 7.5 as mentioned in this policy. 

9. Obligation 

If the complaint is not justified after the investigated but the complainant has the good faith and without malice, the complainant can still submit the other supportive data. However, if the complaint which came from bad faith and with malicious was found after the investigated, that the employees who disclaimed case will be disciplined according to the rules adhered by the company.

 

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