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1. PURPOSE

All employees from AYA SOMPO Insurance both from Headquarters and from branches and regional branch offices can report concerning malpractice and wrongdoing within the workplace. Also, this policy is defined to protect the reporting staff from worry of retaliation or making trouble with wicked mind.

2. POLICY

The Company defined the standards for a higher level of honesty and transparency for taking responsibilities and duties, starting with each employee. The entire company is urged to follow the defined standards and report such issues for better results. Revealing honestly, by believing as staying in line with the standards of the 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 honesty. If the reported employees can explain that malpractice or the related issue was done with innocence.

3. 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.

4. PROCEDURES

The following stages will be conducted in whistle blowing policy

i. 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 other concerns, the employees can use “Reach HR” from HR Application for their convenience. 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.

ii. Second stage procedures

It’s best that the employee could provide 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 the concern. The earlier the employee raise the concern, the easier it will probably be to take effective action.

iii. 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;–

1. The disclaimer cases must take over

with proper care and documented. The disclaimer cases must be reviewed and assessed thoroughly.

2. Authorized person may need the support and suggestion from Legal Unit if the cases are complicated and involve relevant government laws and regulations.

3. The disclaimer cases must be investigated, handled and solved properly without any delay.

4. The root cause of such cases must be identified.

5. Non-discrimination policy must comply at all laws when handling cases.

6. 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 process in their own free 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 persons must keep confidential the name and identity of declaimed employees unless only required for the legal and compliance matter

iv. Fourth stage procedures

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

v. Fifth stage procedures

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

5. 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 (iv) and (v) as mentioned in this policy.

6. OBLIGATION

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