Overview

 

As a responsible business, we have a duty to uphold international human rights laws and standards across all aspects of our operations, supply chains, and business relationships i.e. our employees, clients, suppliers and local communities. 

 

Human rights are fundamental freedoms that must be equally and fairly applied to every individual regardless of race, gender, nationality, religion or any other personal characteristics. This includes promoting fair labour practices and treating all communities with respect, not only as an ethical obligation but also as a social license to operate. By adhering to these principles, we aim to build our reputation as a responsible corporate citizen, which will help to build stakeholder trust for years to come.​

 

Countries, regulators, and lawmakers are increasingly recognising and establishing the right to a safe and healthy environment as a fundamental human right. As such, CIMB’s human rights management incorporates environmental considerations, ensuring a holistic approach to safeguarding the well-being of individuals and communities.

 

Governance​

 

The Group Chief Sustainability Officer (GCSO) and the Group Sustainability Council (GSC) are responsible for managing human rights risks. The Board, through the Group Sustainability and Governance Committee (GSGC), has the ultimate accountability for human rights in the organisation. 

 

Implementation of our Human Rights policy extends to all aspects of our business and is executed by business units and business enablers:
 

  • Group Sustainability oversees the implementation of the Human Rights Policy and Procedure across all aspects of our business. Group Sustainability conducts control testing on these policies and procedures to proactively identify areas for improvement

  • Group Corporate Assurance Division conducts periodic audits to maintain accountability and effectiveness of our policies

  • Relationship Managers from non-retail lines of business conduct Basic Sustainability Due Diligence, which includes a human rights due diligence, on clients in compliance with our Group Sustainability Financing Policy. For cases where a high risk of human rights is identified, Group Sustainability conducts an Enhanced Sustainability Due Diligence

  • Group Strategic Procurement conducts and oversees the sustainability due diligence, including human rights due diligence, on vendors/suppliers during the RFP process and during onboarding of new vendors whereby vendors/suppliers are required to acknowledge the Vendor Code of Conduct

  • CIMB Foundation and our Corporate Social Responsibility function conducts the sustainability due diligence when onboarding new partners

  • Group Human Resources manages complaints received related to employees and unions

Our Group Human Rights Policy

 

The policy aims to provide clarity and transparency on human rights management across the Group. Our Human Rights policy provides guidance on identifying, assessing, and managing salient human rights risks that present the most severe potential negative impacts. This ensures consistency between internal practices and external expectations, including legal and regulatory obligations and voluntary commitments to respect and protect human rights.

 

Within the broader scope of human rights, we focus on issues and risks that are most pertinent to our operations and activities. Our policy not only covers requirements for our own operations, but also encompasses requirements for our business relations such as our clients, suppliers and partners. The policy has been rolled out across the Group in 2023. Read our Group Human Rights Policy here.

 

CIMB commits to continuous human rights due diligence to identify, prevent, and mitigate adverse human rights impacts across the Group through collaborations with our stakeholders. This is done using a risk-based approach, with the greatest attention paid to the areas of greatest risk to the Group and the most salient impacts on people, particularly vulnerable groups. 

Commitments and Frameworks​

 

We commit to uphold and comply with:​

 

  1. The International Bill of Human Rights, including the Universal Declaration of Human Rights (UDHR), International Covenant on Civil and Political Rights (ICCPR), and the International Covenant on Economic, Social and Cultural Rights (ICESCR);​

  2. UN Guiding Principles on Business and Human Rights;​

  3. ILO Declaration on Fundamental Principles and Rights at Work;

 

With regards to labour rights, we commit to the following: ​

 

  1. Avoid causing or contributing to labour rights violations as per national legislation standards. In the event where there is a discrepancy between national, regional, and international standards, we will engage with stakeholders to explore approaches that respect international standards.

  2. Respect the rights of our employees, including:​
    • Freedom of representation; ​
    • Right to collective bargaining;​
    • A safe and healthy work environment, including safety from any forms of harassment, including sexual harassment;​
    • Fair recruitment and other people practices;​
    • Preventing modern slavery; and​
    • Respecting regulations on minimum wage and maximum working hours.
       
  3. Eliminate discrimination in the workplace and promote diversity and inclusion.​

  4. Avoid contributing to, and assist in the prevention of human trafficking.

 

We also adopt principles and recommendations laid out in recognised international, regional and local frameworks, including:​

  • The UN Environment Programme Finance Initiative Principles for Responsible Banking;​
  • UN Sustainable Development Goals;​
  • Bank Negara Malaysia’s Value-Based Intermediation Financing and Investment Impact Assessment Framework and Association of Banks in Malaysia’s ESG Principles​

Our Policy in Action ​

   Employees

We commit to protecting the rights of our employees. This includes their right to freedom of association and ensuring we operate in accordance with local legislation and regulations. We regularly engage employees through focus groups, surveys, town halls, and engagements with union representatives.  

Human rights due diligence is part of our sustainability due diligence in our financing relationship with non-individual clients. Where a client is considered to have high human rights risks, we request that clients have in place commitments and processes to mitigate these risks. In cases of non-compliance with our human rights requirements, we engage with these clients and request them to implement corrective action plans.​​

   Suppliers

We assess actual and potential adverse human rights impacts and how we may have directly caused, contributed to, or linked to an abuse of rights within our supply chain.​ We conduct sustainability due diligence on our suppliers and require them to acknowledge CIMB's Vendor Code of Conduct (VCOC). We will use our leverage to influence them towards the standards outlined in our human rights policy. 

Human Rights and Environmental Grievance Mechanism

 

Aligning with the third pillar of the United Nations Guiding Principles on Business and Human Rights, our Grievance Mechanism serves as a structured process to address and resolve human rights and environmental concerns effectively and transparently.

 

Our Grievance Mechanism is open to all, including CIMB employees, employees of our suppliers and clients, and communities affected by CIMB's operations or those of our business partners, such as indigenous peoples or communities living near a client’s facility. By providing a platform for all stakeholders, we aim to uphold transparency, accountability, accessibility and fairness in addressing human rights complaints.

Channels​

The channels below are categorised based on their availability to different groups of complainants.

Complainants by groups Channels  
All complainants

Email to sustainability@cimb.com;

 

Submit a feedback form through the CIMB website here.

 

Email to whistleblowing@cimb.com OR send via post to the Chairman, Group Audit Committee, CIMB Group Holdings Berhad at 17th Floor Menara CIMB, No. 1 Jalan Stesen Sentral 2, Kuala Lumpur. This is only for wrongdoing of a CIMB employee. This Whistleblowing Channel is jointly and exclusively managed by the Audit Committee Chair of CIMB Group Holdings Berhad and the Group Chief Internal Auditor of CIMB Group.

 
Complainants who are current and former employees of CIMB

Based on the nature, type or category of human rights complaint to be made;

 

Email to  

epicc.culture@cimb.com;

 

Email, phone or write directly to: 

- Chairman of CIMB Group Holdings Berhad,

- Group Audit Committee,

- Group Chief Executive Officer

- Group Chief People Officer and/or

- Group Chief Internal Auditor

 

"Have Your Say" mailbox;

 

Grievance process as provided in Collective Agreements signed with respective unions.

 
Complainants who are current suppliers During supplier engagement sessions.  
Scope​
 

The following criteria will determine whether a complaint is admitted into CIMB's Human Rights Grievance Mechanism:

 

1. Relevance: The complaint must involve an alleged negative human rights impact related to CIMB Group’s operations, lending/financing activities, or business relationships (e.g., clients and suppliers).

 

Refer to the table below for examples of issues that do not meet our criteria.  

Complainants  Examples of non-human rights complaints (non-exhaustive)  
CIMB employees/ Employees of CIMB’s clients/ Employees of CIMB’s suppliers

Disagreements over performance reviews, promotion decisions and/or benefits;

 

Disputes on compensation that do not relate to discrimination due to personal characteristics such as gender and race;

 

Complaints on workplace conditions not related to health and safety. 

 
CIMB non-individual clients

Dissatisfaction with regard to products or services rendered;

 

Disputes over contract terms.

 

 
CIMB suppliers

Dissatisfaction over onboarding and RFP processes; 

 

Disputes over contract terms.

 
Communities

Noise or traffic issues due to a CIMB client’s industrial or commercial activities;

 

Concerns that a CIMB client’s development or business activities may negatively affect local property values;

 

Concerns about the economic competition of new businesses to local businesses;

 

Aesthetic concerns stemming from the construction of new buildings.

 

2. Eligibility to Lodge a Human Rights Complaint: A human rights complaint can be submitted by the individual whose rights are affected or their representatives, which may include not-for-profit organisations, civil society organisations, or legal firms from any country.

3. Timing of the Incident
: If the human rights complaint is against an external party with a business relationship with CIMB, the alleged human rights violation must have occurred when CIMB maintained that relationship.

4. Consent from Business Relations
: CIMB is bound by confidentiality obligations and must obtain a client’s consent before disclosing any information related to them. Where consent is not given, CIMB will still conduct an internal investigation as part of its human rights due diligence, but will not be able to share any information with the complainant.

 

5. Vexatious Complaints: Human rights complaints deemed vexatious (intentionally harassing or disruptive without a legitimate purpose) will not be entertained. The Human Rights Lead will make this determination, which will be approved by the Group Chief Sustainability Officer (GCSO).

6. Escalating Complaints:
If the complaint meets the criteria of another complaints channel (internal employee grievance mechanism or Anti-Money Laundering), it will be escalated to the more appropriate channel.

7. Court Cases
: If the human rights complaint is the subject of an ongoing court case, CIMB will defer processing it until the case is concluded.

 

If a complaint falls outside the criteria of this mechanism, CIMB will inform the complainant of its non-acceptance and provide guidance on other potential avenues for resolution.

We aim to resolve complaints within 12 months. However, this timeline does not include the implementation of any remediation measures, which will vary on a case-by-case basis depending on the complexity and nature of the issue.

Remediation
 

Central to our remediation efforts is prioritising the rights-holder’s interests while ensuring feasibility within the Bank’s regulatory and contractual obligations. Remedies may include apologies, restitution, rehabilitation, financial or non-financial compensation and the prevention of harm.


When we discover that a human rights abuse has occurred, we will take appropriate steps to ascertain whether we have caused or contributed to the adverse human rights impact.

 

  • When we have directly caused these impacts, we are responsible for resolving the issue and providing remedy.
     
  • Where we have contributed to an adverse human rights impact, we will provide mechanisms for grievances to be raised and strive to contribute to remediation, where necessary and appropriate, ensuring no penalty, dismissal, or reprisal.
     
  • Where we have not caused or contributed to an adverse impact, but are directly linked to it through our products, operations or services, we recognise that we can play a role in remediation, for example, by engaging with our clients about their grievance mechanisms and remediation pathway.
Stage Process  
Receive

A human rights complaint is received through any of the channels shared above. 

 
Assess

The human rights complaint is assessed against the criteria to determine its eligibility for acceptance.

 

For complaints involving a non-individual client, CIMB will seek their consent to disclose the relationship and participate in this Grievance Mechanism.

 

The complainant will be informed accordingly on the status of acceptance of the complaint.

 

 
Investigate

CIMB will investigate the human rights complaint, striving to engage in dialogue with the complainant or their representatives and our business relations (where applicable) throughout the process.

 
Respond

We will provide the complainant with periodic written updates throughout the process.

 
Remediate If CIMB determines that it has caused, contributed to, or is linked to any adverse impacts, we will strive to remediate the impact, to the extent of our contribution and accountability.