No Gift Policy / Vendor Code of Conduct / Whistleblowing

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Cagamas is committed to conduct our business in the highest standard of integrity and good governance.

In line with the above commitment, Cagamas adopted a No-Gift Policy effective 1 January 2018 whereby our employees are prohibited from accepting or soliciting any gifts (festive or otherwise) with current or potential customers, vendors, or business partners.

This is to prevent any conflicts of interest, or appearance of such in our business dealings.

We thank you for your continuous support and for observing our “No Gift Policy”.


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1.0 Compliance with This VCOC 

1.1 All vendors shall embrace the spirit of Cagamas Berhad’ commitments to integrity and shall adhere to this VCOC.

1.2 The VCOC shall apply to all contractors, consultants and agents of Cagamas and to any person(s) appointed by them in any capacity to deliver the goods or perform any part of the services, including their employees, agents, suppliers and subcontractors (“their representative”). Cagamas expects its vendor(s) to comply with the VCOC when engaging with Cagamas and in conducting business with Cagamas.

1.3 Before the commencement of the services, it is the responsibility of the vendor(s) to ensure that its representative(s) understands and complies with this VCOC. The vendor(s) must inform Cagamas if the vendor(s) knows, or has reason to believe, that a violation by it or its representative(s) may have occurred or is likely to occur in the future.

1.4 Cagamas, may from time to time, require the vendor(s) to provide attestation in writing of its compliance with this VCOC, and expects the vendor(s) to provide Cagamas with responses to Cagamas’ request for information about compliance with this VCOC. Cagamas expects that all vendors will cooperate with the Bank in any investigation the Company may conduct.

1.5 Cagamas reserves the right to take action on the vendor(s) for breaching the VCOC. In case of non-compliance with the VCOC, the Company may take one or more the following actions:

(a) a revocation of offer for tender or quotation;

(b) a termination of contract;

(c) a deduction of any amount paid or to be paid from the purchase price;

(d) blacklist from Cagamas’ Approved Panel/Suppliers List

(e) Any other action that the Company deems fit.


2.0 Principles of the Code

2.1 The following principles support the core values of the Company and should be adhered to:

Act with Integrity

Vendors will conduct all procurement and business relationships with integrity, respect and trust and will not disclose confidential or competitive information or data to any unauthorised third party unless required by law.

Vendors must have appropriate policies, procedures and security controls in place to protect the Company’s confidential / competitive information and prevent any information leakage.

Vendors must comply with the Company’s policies and the applicable laws on protection of personal privacy, including personal data

Maintain Accountability Vendors will maintain full accountability for goods provided/services rendered and honour their commitment on a timely basis and in accordance with obligations under the specific agreements or undertaking with Cagamas.
Avoid the appearance of or actual conflict of interest

Vendors with actual or potential conflict of interest are expected to declare in writing to Cagamas even if the knowledge arises after appointment and to take action to proactively address the conflict as soon as it is aware. If in doubt it should be highlighted to Cagamas

Cagamas prohibits vendors from gaining improper advantage in their relationship with Cagamas’ employees. The vendor is required to disclose to the bank in writing if they have any family connection with any of the Cagamas’ staff.

If at any point of time a situation of actual or potential conflict of interest arises, the vendor must inform Cagamas in writing of the circumstances as soon as they become aware of the situation

* Family connection refers to spouse, children and their spouses, parents and in-laws, siblings and their spouses and children.

Abide by the rule of law Vendors will comply with all applicable laws and regulations and will avoid practices which will give rise to charges of bribery, corruption and prohibited business practices.
Honest representation Vendors will provide honest and open representation of its organisation, its qualification, its experience and its capabilities in delivering goods and services to the Company. Vendors will also disclose accurate references of previous work or engagements which they have undertaken. /td>
Prohibit any form of gift/business courtesy to procure favours and/or unfair advantage Vendors will never directly or indirectly soliciting any offer a bribe, kickbacks, bartering arrangement for goods and services or cash or any other incentives to Cagamas’ employees and/or their families in order to obtain or maintain Cagamas’ business. Vendors should report to Cagamas if any Cagamas employees or business associates request for such incentives. During bid or evaluation process, vendors should refrain from entertaining or treating Cagamas employees involved in the evaluation and/or their families such as providing special invitation to event or function. Any gifts given or received must be in compliance with the law and must not violate the giver’s and receiver’s policies on such practice. Cagamas adopts a “No gift Policy”.


3.0 Reporting of Potential Breach

3.1 Any party with knowledge of a potential or questionable breach of this VCOC, may report to any of the following Authorised Officers:

  • Chief Executive Officer
  • Chairman of the Board of Directors; or
  •  Chairman of the Group Board Audit Committee

3.2 If the complaint is against the Chief Executive Officer, the report should be submitted to the Chairman of the Board of Directors and if the complaint is against the Chairman of the Board of Directors, the report is to be submitted to the Chairman of the Group Board Audit Committee.

3.3 All information will be promptly reported to the appropriate channels, and will be handled with the utmost discretion. The identity of the concerned reporting party will be treated with the strictest confidentiality at all times, unless otherwise provided by the Company’s policies and guidelines, required by law or for the purpose of any proceedings by or against the Company. Cagamas will not tolerate any retaliation taken by its employees, or vendor(s) or its representative(s) against any individual for reporting in good faith questionable behaviour or possible violation of the VCOC.

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Cagamas expects the highest standards of integrity from all its employees and vendors. It takes a serious view of any improper conduct on the part of any of its employees, Management, Directors and Vendors, in particular with respect to their obligations to the Company’s interests.

The Whistleblowing channel is established to help stakeholders raise concerns, without fear of retaliation, on any improper conduct that they may observe in the Company.

The following FAQ on Whistleblowing serves as a guideline for Cagamas stakeholders to report a Whistleblowing complaint to the Management of Cagamas for action.

Whistleblowing is an act where stakeholders report improper conduct to Management for action.

Improper conduct shall also include but not limited to the following:

  1. Conduct which constitutes a criminal offence under the law such as fraud, bribery, forgery, cheating, theft, embezzlement, criminal breach of trust, abetting or intending to commit criminal offence;
  2. Conduct which is in contravention of the established written policies and guidelines including but not limited to breach of confidentiality, abuse of power or misuse of the Company’s resources;
  3. Failure to comply with statutory obligations;
  4. Any other conduct that undermines the ethical values of the Company or may cause loss / detrimental to the interest of the Company; or
  5. Any attempt to conceal or suppress information relation to the above.

Whistle-blower who acts in good faith will be accorded protection, subject to appropriate action, up to and including legal action.

Acting in good faith means acting without malicious intentions and in the better interest of the Group.

Yes, your identity will be kept confidential. However, your consent will be sought should there be a need to disclose your identity for investigation purpose.

  1. The complaint can be submitted to any of the following Authorised Officers:
    • Chief Executive Officer
    • Chairman of the Board of Directors;
    • Chairman of the Group Board Audit Committee 
  2. If the complaint is against the Chief Executive Officer, the report should be submitted to the Chairman of the Board of Directors and if the complaint is against the Chairman of the Board of Directors, the report is to be submitted to the Chairman of the Group Board Audit Committee.
  3. A whistle-blower should not submit a report to a designated officer who is the subject of reporting.

The complaint can be submitted as follows:

  1. Print the Whistleblowing Information Form on Cagamas’ website
  2. Complete the Form.
  3. Attach the relevant documents
  4. Place in a sealed envelope with the phrases "Strictly Confidential" and "To be opened by Addressee only” on left hand corner of the envelope.
  5. State the name of the Authorised Officer you want to address the complaint to (Refer to Q 6 above)
  6. Deliver or send to Cagamas Berhad, Level 32, The Gardens North Tower, Lingkaran Syed Putra, Mid Valley City, 59200 Kuala Lumpur

Yes, you can. Kindly deliver or send your request in writing, stating the reason for withdrawal.


Download Whistleblowing Information Form