My Company My Business

Introduction

The Guidelines to My Business

Our Assurances to Our Employees

How Our Employees Can Raise Their Concern

How the Company Will Respond

People within our organisation are concerned about the negative impact that a breach of the Shell General Business Principles (SGBP) may have upon the ability of Shell Refining Company (Federation of Malaya) Berhad (SRC) to achieve its corporate objectives and the damage it may cause to your Company’s image and reputation.

Equally, there may also be concerns that SRC is not realising maximum and optimum benefits from available opportunities, whilst operating within the boundaries of the SGBP. Some people may feel that speaking out would be an act of disloyalty to their colleagues, their manager or even to the organisation. All are valid concerns, more so if the employee caught in such situations feels that nothing they do will make a difference and go on to keep their concerns to themselves.

In SRC, each employee is fully aware that they must do something to make a difference because what goes on in the Company is their business!

Employees may have knowledge of actual or potential breaches of Shell General Business Principles or about the integrity of processes and procedures being compromised. Employees may also have ideas or suggestions about how our business opportunities could be better realised, but do not seem to have found someone willing to hear out their ideas, or bold enough to seek Management authorisation to put the ideas into action. They may have said something already but to the wrong person or in the wrong way.

The Directors and Management of SRC are committed to making it an acceptable practice for employees to raise genuine concerns or offer constructive suggestions about business issues and opportunities. They are equally committed to responding to employees who do so.

This guideline has been introduced to provide a safe and acceptable way for our employees to raise their concerns about malpractices at an early stage and in the right way as well as about business improvement opportunities. The aim of this guideline is for our employees to raise a matter so that it can be addressed in an independent and unbiased manner. Our employees are not required to prove their case. However, they will need to provide sufficient information for the Management to take appropriate steps.

This Guideline on My Company is My Business is primarily for raising concerns where the interests of the organisation or its stakeholders are at risk, either by a breach of a process/ procedure, or where beneficial business opportunities may be missed.

If however, our employees are aggrieved about matters that concern them personally or may have a vested interest in the outcome, they can adopt the Grievance Procedure which can be found in the Personnel Policies and Procedures Manual.

If our employees raise a genuine concern, they will not be at risk of any form of victimisation or retribution from SRC or from any of its Directors/ Management provided they are acting in good faith. It does not matter if they are mistaken. This assurance does not however extend to employees who are found to have raised a matter falsely or maliciously. If our employees wish to raise their concern anonymously or with their identity known only to specific persons, this will also be respected.

Any attempt at retaliation or intimidation against anyone making a report in good faith is a serious violation of our Code of Conduct and will be dealt with appropriately.

In SRC, our employees can raise their concerns first with their immediate supervisor or line manager. If they are unable to do this for any reason, they can use any of the methods below:

• They can raise a concern in confidence. If they request for their identity to be protected, it will certainly not be disclosed without their consent. However, a situation may arise where it will not be possible to resolve the matter without revealing their identity. Under these circumstances, the approach on how best to proceed will be discussed with the respective employee.

• Alternatively, they can raise a concern anonymously. However, they will need to provide sufficient facts and data to enable Management to look into the matter without their direct assistance. It is made known to the employees that if they do not tell who they are, it may be more difficult to look into the matter, especially if the facts supplied by them are found to be insufficient. It may also be difficult to protect their position or to give them feedback.

To raise concerns in confidence or anonymously, our employees can call or personally visit/ write to the appointed focal points in the Company.

Once an employee has disclosed his/ her concern, the following steps will be taken:

1. Receipt will be acknowledged (if the employee has disclosed his/ her identity).
2. An initial assessment of the matter will be made to decide on what action is appropriate.
3. The Company will inform the respective employee on the way in which the matter will be progressed. If that employee has a personal interest in the matter, he/ she will be required to disclose this at the onset and where his/ her concern falls more appropriately within the Grievance Procedure; he/ she will be advised accordingly.
4. The respective employee will be provided with feedback on actions taken if he/ she has requested for this. However, the Company may not be able to provide to the respective employee a full disclosure where this infringes the Company’s duty of confidentiality to another person or persons.

Raja Ahmad Murad

Managing Director

Shell Refining Company (Federation of Malaya) Berhad