Whistle Blowing Policy


The following procedures have been adopted by the TZAM Management Team to
govern the receipt, retention and treatment of complaints and to protect the confidential
and anonymous reporting of the same. These policies and procedures are available to
all employees of the Company and external stakeholders.


The policy coverall all employees of Toyota Zambia Limited and external stakeholders.

Responsibility and Ownership

The Company will endeavour to ensure that appropriate prevention and detection
controls are applied, however it is the responsibility of Employees and the Managers to
report all incidents of fraud, corruption, theft, maladministration or any other dishonest
The Company will take appropriate legal recourse to recover losses or damages arising
from fraud, corruption, theft or maladministration.
In view of the legal framework and the Company’s policy, any Employee who shows
disregard to the Company’s policy will be dealt with in terms of the Company’s
disciplinary procedure.


Employees have the opportunity to submit/report complaints pertaining to the following
areas such as:

  • Providing information to the Risk and Assurance Manager or Management which
    leads to the prevention of theft and recovery of stolen assets
  • Violating of any rules and regulations applicable to the Company and related to Accounting, Internal Accounting and controls and auditing matters
  • Intentional error or fraud in the preparation , review or audit of any financial statements of the Company
  • Any violation to the Company’s ethical business practices as specified in TZAM’s Staff Manual Policies
  • Any other event , which would affect the interests of the business
  • Corruption, criminal activities etc
  • A reward will be paid to informant and will be authorized by the Managing Director subject to a scale of 10% of the value of the subject matter recovered to the maximum of $1000.

Toyota Zambia will protect the confidentiality and anonymity of the Complainant to the
fullest extent possible with an objective to conduct a review. External Stakeholders such
as vendors, customers, business partners etc have the opportunity to submit complaints;
however the Company is not obligated to keep the complaints from non employees
confidential but will maintain the anonymity of non employees. However, individuals are
encouraged to send complaints/raising any matter by identifying themselves as it will
assist in the complaints review process.

Receipts and Treatment of Complaints

  • The Risk and Assurance Manager is the primary receipt of all Whistle-Blower
  • Complaints reported are investigated by the Risk Management Team
  • The person/persons against or in relation to whom the Complaint is made shall
    cooperate with the investigator and have the right to provide their inputs during
  • The Risk and Assurance Committee shall comprise the Managing Director,
    National HR Manager, Finance Manager and the Risk and Assurance Manager.
  • The Risk and Assurance Committee shall meet every so often when necessary
    to consider any issues that may arise.

Access to Reports and Records and Disclosure of Investigation Results

All reports and records associated with Complaints are considered confidential
information and access shall be restricted to Risk and Assurance Manager and the Risk
and Assurance Committee. Reports or resulting actions will generally not be disclosed to
the public except as required by any legal requirements or regulations or any corporate
policy in place at that time.

Retention of Records

All documents relating to such Complaints made through the procedures outlined above
shall be retained for at least six years from the date of the complaint after which the
information may be destroyed unless the information may be relevant to any pending or
potential litigation, inquiry or investigation in which case the information shall be retained
for the duration of that litigation, inquiry or investigation as deemed necessary.


Managers should discourage employees and officials from making allegations which are
false and made with malicious intentions. Where such malicious or false allegations are
discovered, the person who made the allegations must be subjected to firm disciplinary
action as outline in the Toyota Zambia Staff Manual.

Policy (PDF)