SECTION 1: OBJECTIVES
The policy is created to comply with the requirements of Guideline 11.7 of the Singapore Code of Corporate Governance 2005. The purpose of this policy is to:
1.1. Provide an avenue for employees to raise concerns about fraud or malpractice with- in the Company and its subsidiaries which they have become aware of
1.2. Provide reassurance that the employees will be protected from reprisals or victimization for whistle blowing made in good faith and without malice.
SECTION 2: STATEMENT OF POLICY
AYA SOMPO Insurance Company Limited is committed to the highest standard of quality, honesty, openness and accountability, and encourages employees with serious concerns to come forward to express those concerns. Employees raising concerns in good faith can do so without fear of reprisal or victimization. The Company is committed to this policy. Employees who raise genuine concerns under this policy should not feel they are at risk of losing their job or suffering any form of retribution as a result. Provided they are acting in good faith, it does not matter if employees are mistaken or if there is an innocent explanation for their concerns.
SECTION 3: SCOPES
This policy applies to all full-time, part-time and contract employees of AYA SOMPO Insurance Company Limited. This policy is intended to deal with serious or sensitive concerns about such as the following:
3.1. Financial frauds and malpractice
3.2. Unauthorized use of Company money
3.3. Corruption
3.4. Unlawful acts
3.5. A person abusing his/her position for any unauthorized use or for personal gain
3.6. Non-adherence to major control policies (for example, removing of assets without proper approval)
3.7. Deliberately conceal information tending to show any to show any of the above.
This policy is not covering the following:
3.8. A person being discriminated against because of their race, color, religion, ethnic or national origin, disability, age, sex, home life, etc.
3.9. Staff complaints about their employment. These complaints are dealt with through – Grievance Handling Policy Customers’ complaints about our products/services.
3.10. These complaints are dealt by the Customer Care Services
SECTION 4: PROCEDURE TO FOLLOW
Stage – 1 Who to Raise a Concern to
You can approach your immediate Director, Manager or our appointed Whistle Blowing. If you feel unable to raise the matter with your immediate Manager or our appointed Whistle Blowing Officers for whatever reason or are not satisfied with the outcome of initial investigation, you can raise the matter up with the CEO, either personally or via e-mail. If the above channels have been followed and you still have concerns or if you feel that the matter is so serious that you cannot discuss it with any of the above, you can e-mail only to the Chairman of Audit, Risk and Compliance Committee.
Stage – 2 How to Raise a Concern
It is best that you could provide them with as much information as possible, including any relevant names, dates and places and so on. You will have to show them that there are good reasons for your concern. The earlier you raise a concern, the easier it will probably be to take effective action.
Stage – 3 How We Respond to Your Concern
In dealing with your concern under this Policy, the Chief Executive Officer and or appointed whistle blowing officers have a responsibility to:
a) Take concerns seriously.
b) Consider them fully and sympathetically.
c) Recognize that raising a concern can be a difficult experience for you and to offer support.
d) Investigate and resolve the matter as quickly as possible.
e) Ensure that you are informed of the outcome of the matter.
f) Ensure that there is no victimization of your raising concerns.
g) Ensure that protection is offered if the concern comes with the legal definitions covered by established laws or legislation.
h) They may require you to meet them during the investigation process. The amount of contact you have with them will depend on the nature of your concern, the potential difficulties involved and how clear the information you have provided. Meetings with whistle blowing officers will normally take place in the Head Office. You may be accompanied by a friend or colleague during the meeting.
i) They will keep your concerns confidential and will not reveal your name or position without your per- mission or unless they have to do so by law.
j) If the concern later turns out not to be justified, but was raised in good faith and without malice, you can still expect support. However, if you have raised a concern that later turns out to be malicious or brought in bad faith, you will be disciplined accordingly. Any staff who try to discourage his/her col- leagues from coming forward, or criticize or victimize them after voicing a concern, will be disciplinary dealt with.
Stage – 4 Monitoring & Documentation Concerns
Whistle blowing officers will maintain a record of concerns raised under this policy, the outcomes and areas of improvement (in a form which does not endanger confidentiality and where applicable, protects the identity of the complainant).
Stage – 5 Periodic Reporting
The whistle blowing officers will report the concerns received, outcome of each investigation conducted and action plans for improvement to the Chair of the Audit, Risk and Compliance Committee during the quarterly Audit, Risk and Compliance Committee Meetings.
SECTION 5: PROTECTION FOR WHISTLEBLOWER
The company will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistleblower who believes he/she is being retaliated against must contact the Human Resources Director immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.
5.1. The company may not discharge, threaten, or otherwise discriminate against an employee regarding the employee’s compensation, terms, conditions, location, or privileges of employment.
5.2. The organization may not disqualify an employee or other person who brings a matter of public concern or participates in a proceeding connected with a matter of public concern, before a public body or court, because of the report or participation, from eligibility to bid on contracts with the organization; receive land under a district ordinance; or receive another right, privilege, or benefit.
Limitation to protections
A person is not entitled to the protections under this policy unless he or she reasonably believes that the information reported is, or is about to become, a matter of public concern; and reports the information in good faith.
A person is entitled to the protections under this policy only if the matter of public concern is not the result of conduct by the individual seeking protection, unless it is the result of conduct by the person that was required by his or her employer.
SECTION 6: REVIEW OF POLICY
This policy shall be reviewed annually by senior management. Any changes to the policy shall be communicated immediately to all responsible people.
WHISTLEBLOWER REPORT FORM
When you visit our web site, you may see that we use “cookies” in interacting with your web browser. A “cookie” is a piece of information that a website transfers to your computer hard drive for record keeping purposes. The cookie cannot be read by a web site other than the one that set the cookie. We use cookies for a number of administrative purposes; for example, to store your preferences for certain kinds of information or to store a password so that you do not have to input it every time you visit our web site. Most cookies last only through a single session, or web site visit. None will contain information that will enable anyone to contact you via telephone, e-mail, or any other means. You can set up your Web browser to inform you when cookies are set or to prevent cookies from being set.
Cookies are small text containing small amounts of information which are downloaded and may be stored on any of your web browsers or internet enabled devices that can later be read by the server – like a memory for a web page.
This means we automatically collect and store the following information about your visit:
the internet domain and IP address from where you access the website;
the type of browser software and configuration and operating system used to access the website;
the date and time you access the website;
if you linked to the website from another website, the address of that website; and
the pages you enter, visit and exit the website from, content viewed and duration of visits.
We use cookies to improve your experience when you browse our websites (for example to show you information that’s relevant to you, based on the sort of web content you’ve looked at before) and to save you time by not having to re-enter your details each time you visit. We also use cookies to see how people interact with our websites, so we can make improvements to the site that make it easier to use.
Cookies that are required for the operation of the website and enable you to log into secure areas of the website is called strictly necessary cookies. Analytical/performance cookies allow us to recognize and count the number of visitors and to see how visitors move around and use our website. These cookies are used for web enhancement and optimization purposes and to aggregate statistics on how our visitors reach and browse our websites. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and to help us understand what interests our users, and measure how effective our advertising is. Functionality cookies are used to recognize you when you return to the website. This enables us to personalize our content for you, tailor the website for your needs and remember your preferences, for example, your choice of language or region, browsing font size. Cookies that record your visit to the website, the pages you have visited and the links you have followed is called targeting cookies. We will use this information to make our website and any material displayed on it more relevant to your interests. We may also share this information with third parties for this purpose; and advertising cookies will remember your preferences, and in general, that your used the website, to tailor advertising to you that are as relevant to you as possible, e.g. by selecting interest-based advertisements for you, or preventing or limiting the number of times you see the same advertisement to help measure the effectiveness of advertisements.
We may also use analytics companies and third-party service providers to gather information and aggregate data from our website visitors such as which pages are visited and how often they are visited, and to enable certain features on our websites. Information is captured using various technologies and may include cookies.
We may use and disclose your activity information unless restricted by this policy or by law. Some examples of the ways we use your activity information include:
1. Marketing, product development, and research purposes
2.Developing reports regarding website usage, activity and statistics
3.Customizing your experience on the website including managing and recording your preferences.
4.Enabling certain functions and tools on this website.
5.Tracking paths of visitors to this website and within this website.
6.Assisting users experiencing website problems.
7.Tracking resources and data accessed on the website.
AYA SOMPO Insurance Company Limited and its subsidiaries recognize our responsibilities in relation to the collection, use, disclosure and other processing and storage of personal data. Customers and potential customers expect us to maintain their information accurately, protected against manipulation and errors, secure from theft and free from unwarranted disclosure. We protect data security of our customers and potential customers by complying with the all relevant data protection laws and regulations.
We maintain reasonable administrative, technical and physical safeguards designed to protect the information that you provide on this website. However, no security system is impenetrable and we cannot guarantee the security of our website, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the internet, and we are not liable for the illegal acts of third parties such as criminal hackers.
We may also share personal information with other third-party companies that we collaborate with or hire to perform services on our behalf. For example, we may hire a company to help us send and manage email, and we might provide the company with your email address and certain other information in order for them to send you an email message on our behalf. Similarly, we may hire companies to host or operate some of our websites and related computers and software applications.
We collect and store your personal information with the two ways,
Directly- the personal data that you provide to us (for example, when you use enquiries or communications)
Indirectly- when you use our website, apps or social media platforms, or where you have provided it to us through any other means.
We may obtain lawfully collected personal or non-personal data about you from affiliated entities, business partners and other independent third parties’ sources. We may also collect some information about your computer or other devices used when you visit this website, apps or social media platforms.
The personal data we collect includes the following:
Identity Information – name, address, personal contact details including email address and telephone numbers and
Technical Information – such as IP address, browser type and version, time zone settings, browser plugin types, operating systems and platform, device information including where mobile device the IMEI number, wireless networks and general network information.
to design new or enhance existing products, information and services provided by us;
to process and administer your account, to implement and effect the requests or transactions contemplated by the forms available on our website or any other documents you may submit to us from time to time;
to provide you with access to the content on the website, apps or social media platforms;
to monitor your use of the website, apps and social media platforms and conduct analysis of the use of the website in order to operate, evaluate and improve the website and our services, understand your preferences and troubleshoot any problems;
to personalize the appearance of our websites, provide recommendations of relevant products, information and services and provide targeted advertising on our website or through other channels and
for the purpose of more effective marketing
“AYA SOMPO” and its logos are registered trademarks of AYA SOMPO Insurance Company Limited. Except as indicated otherwise, all intellectual property, especially copyright and trademark rights, and similar rights in the information, text, graphic images, logos, features or functions, and layout contained on ayasompo.com are the exclusive property of AYA SOMPO, and may not be copied, reproduced, posted, transmitted or distributed, in whole or in part, in any form without first having obtained AYA SOMPO’s express written consent.
Nothing on ayasompo.com should be construed as granting a license or any other right to use any copyrights, trademarks or logos. Moreover, the downloading or printing of any materials on ayasompo.com will not result in the transfer, explicit or implied, of any rights. You may, download or print any pages from ayasompo.com for personal, non-commercial use only, provided you do not remove any copyright or other proprietary right notice.
The copyright in some documents and other material available on ayasompo.com may belong to third parties and such documents and other material have been produced on ayasompo.com with the permission of the third-party copyright owners. You must check copyright notices on or in respect of such documents or material.
Some of the links from ayasompo.com to other websites are provided for your information and convenience only.
A link from ayasompo.com to another website or a link from another website to ayasompo.com does not constitute a referral, endorsement, approval, advertising, offer or solicitation with respect to such website, its contents, or any products or services advertised or distributed through that website. AYA SOMPO believes that the links provided to other publicly accessible websites, webpages, newsgroups, and other sources is legally permissible and consistent with the common, customary expectations of those who make use of the Internet.
These Terms of Use are subject to amendments and changes at any time at AYA SOMPO’s sole discretion. Accordingly, we suggest that you check these Terms of Use periodically for updates.
With the approval of the Ministry of Planning, Finance and Industry of Myanmar, AYA Myanmar General Insurance Company Limited has entered into a joint-venture with Sompo Japan Nipponkoa Insurance Inc, resulting in a new JV company, AYA SOMPO Insurance Company Limited effective 1st January 2020, conducting GENERAL INSURANCE Business in Myanmar. AYA SOMPO Insurance Company Limited was issued with Joint Venture license from Ministry of Planning, Finance and Industry on 28th November 2019.
AYA SOMPO Insurance provides people in Myanmar with a sense of assurance and certainty.
1. The future is unknown, but planning ahead together with AYA SOMPO will help manage the uncertainties of tomorrow and give customers peace of mind.
2. AYA SOMPO leads the way in providing customer-centered solutions that are simple, accessible. It informs and educates, promoting financial literacy and financial inclusion for the nation.
3. AYA SOMPO is driven by the innovative spirit to deliver ever-better products and services. And we build up human capital beyond our company needs, for the needs of the country.
AYA SOMPO shall continually improve the effectiveness of the quality management system through the use of the quality policy, quality objectives, audit results, analysis of data, corrective and preventive actions and management review.
AYA SOMPO to further improve customer convenience and services. By investing not only capital but also our group’s advanced technologies and human resources in AYA SOMPO, we will strive to achieve sustainable growth in AYA SOMPO’s business performance and improve its governance. In addition, we will contribute to the penetration of 11 insurance II and the development of the marketing Myanmar.
Through our experience, AYA SOMPO shall also adhere and comply with the regulatory requirements. We are beyond an insurance company; we form a part of shaping Myanmar’s future.
The Board believes that strong corporate governance is an important part of our company culture as it emphasizes on having the appropriate people, processes, and structures to direct and manage the business and affairs of the Company to enhance long-term shareholder value, whilst taking into account the interests of other stakeholders. Companies that embrace the tenets of good governance, including accountability, transparency, and sustainability, are more likely to engender investor confidence and achieve long-term sustainable business performance.
BOARD OF DIRECTORS
The Board of Directors of the Company has the dual role of setting strategic direction, and of setting the Company’s approach to governance. This includes establishing an appropriate culture, values and ethical standards of conduct at all levels of the Company. The role of the Board is therefore broader than that of providing oversight. A well-constituted Board fosters more complete discussions, leading to better decisions and enhanced business performance.
The Company is headed by an effective Board which (i) is collectively responsible for the long- term success of the Company and (ii) works closely with management bodies and personnel who have authority and responsibility of planning, directing, and controlling the activities of the Company.
Good corporate governance is good for the Company, as a well-governed company is better placed to perform over the longer-term. A sustainably successful Company is good for myriad stakeholders, employees, suppliers, customers, shareholders, as well as society at large.
Specific areas of responsibilities of the Board are:
BOARD COMPOSITION
The Board has an appropriate level of diversity of thought and background in its composition to enable it to make decisions in the best interests of the Company.
BOARD MEMBERSHIP
The Board has a formal and transparent process for the appointment and reappointment of Directors, taking into account the need for progressive renewal of the Board.
The shareholders of the Company must elect or nominate Directors who: at a minimum, (i) would fulfil the fit and proper criteria imposed by the Financial Regulations Department of the Ministry of Planning and Finance of Myanmar, and (ii) has demonstrated integrity by his/her personal behavior and business conduct, soundness of judgement and financial soundness; have established expertise in information technology, finance and management such as accountancy, law, insurance, banking, economics etc. with qualifications and experience that is appropriate to the Company; are able to allocate sufficient time to the Company to discharge his/her responsibility effectively;(in the event of re-election or nomination of a previous Director) has received positive results of performance from the Board. The Board establishes a Human Resource and Remuneration Committee to make recommendations to the Board on relevant matters relating to:
The Human Resource and Remuneration Committee ensures that new Directors are aware of their duties and obligations. The Human Resource and Remuneration Committee also decides if a director is able to and has been adequately carrying out his or her duties as a Director of the Company.
ACCOUNTABILITY AND AUDIT
Risk Management and Internal Controls
The Board is responsible for the governance of risk and ensuring that Management maintains a sound system of risk management and internal controls, to safeguard the interests of the Company and its shareholders. The Board shall be responsible for the oversight over the control functions of the Company.
The Board determines the nature and extent of the significant risks which the Company is willing to take in achieving its strategic objectives and value creation. The Board sets up a Board Risk Committee to specifically address this, if appropriate. The Board lays down the policy framework to put in place:
(i) the CEO and the head of finance that the financial records have been properly maintained and the financial statements give a true and fair view of the Company’s operations and finances; and
(ii) the CEO and other Key Management Personnel who are responsible, regarding the adequacy and effectiveness of the Company’s risk management and internal control systems.
INTRODUCTION
AYA SOMPO Insurance is strongly aware that Money Laundering and Terrorist Financing will be highly damaging to an insurance company’s image, reputation and the insurance company may suffer legal risk. The Company is committed to the highest standards of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) compliance and requires management and employees to adhere to these standards to prevent use of our products and services for Money Laundering and Terror Financing purposes.
AML/CFT strategies, goals and objectives will be maintained in an effective Anti-Money Laundering procedures manual for the insurance’s business that reflects the best practices for a financial institution.
The Company’s AML/CFT policy is the responsibility of all staffs. The policy includes client screening and monitoring requirements, “Know Your Customer (KYC)” policies, Sanction Policies, record keeping requirement, the reporting requirements of threshold transactions and suspicious transactions and AML/CFT training.
RELEVANT LAWS AND REGULATION
The Company is practicing to comply with the following laws and regulations;
1. The Anti-Money Laundering Law of Myanmar (The Pyidaungsu Hluttaw Law No.11/2014)
2. The Anti-Money Laundering Rule of Myanmar
3. The Counter Terrorism Law of Myanmar
4. IBRB’s Directive No. (4/2019)
5. Consolidated United Nations Security Council Sanction List
6. Sanction Regulations by Office of Foreign Asset Control (OFAC), U.S. Department Of The Treasury
DEFINITION OF MONEY LAUNDERING
Money Laundering is defined as the following in Section 3(n) of Anti-Money Laundering Law of Myanmar;
1. Converting or transferring of money and property, knowing or having reason to know that it is money and property obtained by illegal means for the purpose of disguising or concealing the source or for the purpose of assisting before or after commission of the offence to any person who is involved in the commission of any offence to evade the legal action;
2. Changing the true nature, source, location and disposition of money and property, knowing or having reason to know that it is money and property obtained by illegal means and conceal or disguise of ownership or rights of such money and property;
3. Acquiring, possessing or using of money and property, knowing or having reason to know at the time of receipt that it is money and property obtained by illegal means;
4. Participating, facilitating, aiding, supporting, managing, counseling, being a member of an organized group in committing, attempting to commit or conspiring to commit any offences.
KNOW YOUR CUSTOMER (KYC) POLICY
Know Your Customer (KYC) policy helps to build our relationship with customers. It includes the following processes;
1. Acceptance Application Proposal
2. Proposal Identification
3. Proposal reviewing process
4. Specific issue for insurance company
5. Debit Note issue for Wire Transfers
Customer Due Diligence shall be applied to customers, based upon customer risks, product risks and geographical risks. Enhance Due Diligence shall be applied to high-risk customers. The Company would not do business with shell insurer or AML/CFT regime country and would not provide the products and services to those.
RECORD KEEPING
According to the Section 23 of Anti-Money Laundering Law of Myanmar. The Company shall maintain the records of the necessary information at least 5 years under local laws and regulations.
LOCAL BLACK LIST AND INTERNATIONAL SANCTIONS
The Company Sanctions producer is designed to ensure that our company with applicable local black list and international sanction regulations.
ROLES AND RESPONSIBILITIES OF COMPLIANCE OFFICER
Compliance Officer of Head Office shall be approved by Chief Executive Officer. Compliance Officer of Head Office are specified in the section 28 (b) of the Anti-Money Laundering Law of Myanmar.
Branch Manager and Head of Department shall be appointed to perform proper AML/CFT responsibilities of report to Compliance Officer.
REPORTING
Branch Manager and Head of Department are, case by case, receive US$15,000/- (equivalent MMK 22,000,000/-) shall be reported to Head of Finance, Head of internal Audit and Compliance Officer.
TRAINING
All new staff shall receive the AML/CFT awareness training within six months after an employee has joined the Company. The Advanced AML/CFT training and workshops will provide to specific level of staffs occasionally.
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