Policy Statement

The Company is fully committed to complying with applicable laws and regulations pertaining to anti-bribery and corruption. Breaches or violations of these laws can have severe repercussions for the Company, including reputational damage, legal penalties, imprisonment for those responsible, potential loss of business opportunities, and the departure of key personnel.

The Company and its Board of Directors maintain a zero-tolerance stance towards bribery and corruption. Under no circumstances shall the Company engage in or accept any form of corrupt gratification from any individual or entity, for any purpose.

This unwavering commitment extends throughout the Company’s operations, and it expects all stakeholders, both internal and external, to adhere to the same principles. This applies to all business dealings and transactions in the countries where the Company operates.

Directors, employees, suppliers, service providers, business associates, consultants, and any other third parties affiliated with or working for the Company (collectively referred to as “Associated Persons”) are required to comply with and uphold the Company’s anti-bribery and corruption position as outlined in the Company’s Policy.

Any violation of this Policy will be treated seriously by the Company. Appropriate actions, including but not limited to employment or appointment reviews, contract assessments (including contract termination), disciplinary measures, dismissal, and reporting to the authorities, will be taken in accordance with relevant laws and regulations.

Scope of Policy

This Policy applies to all individuals and entities classified as Associated Persons, which encompass a wide range of roles within the Company and its subsidiaries, associates, and related companies. Associated Persons include but are not limited to employees (including directors, trainees, casual workers, volunteers, interns, whether on a temporary, contract, or permanent basis), suppliers, service providers, business associates, consultants, contractors, agents, sponsors, intermediaries, or any other person working for or with the Company, regardless of their location (within or outside of Malaysia). The definition of Associated Persons aligns with Section 17A(2) of the MACC Act 2009.

Within the context of this Policy, a third party refers to any individual or organization that our Company engages and collaborates with. This encompasses current and prospective clients, customers, suppliers, consultants, service providers, distributors, business contacts, agents, advisers, as well as government and public bodies. It also includes their advisors, consultants, representatives, officials, politicians, and public parties.

Any agreements or arrangements entered into by our Company with third parties are subject to well-defined contractual terms. These terms incorporate specific provisions that mandate compliance with minimum standards and procedures relating to anti-bribery and corruption.

Conflicts of Interest

A conflict of interest arises when an individual or organization is involved in multiple interests, where one interest has the potential to corrupt, or be perceived as corrupting, the motivation for actions related to another interest. These conflicts can be actual, potential, or perceived, and they may be of a financial or non-financial nature.

Associated Persons must exercise caution when it comes to their personal relationships with customers, suppliers, competitors, or businesses associated with a customer or supplier. The purpose of this caution is to ensure that no obligations arise that could bias or influence the business relationship or create conflicts with their responsibilities. In the event of a conflict of interest between employees and a third party, the employees or the relevant department head should be notified, and it should be reported to a director.

Associated Persons are obligated to avoid any situation or activity that compromises, or has the potential to compromise, their judgment or ability to act in the best interests of the Company. They must also refrain from putting themselves in a position where their personal interests conflict, or could potentially conflict, with the interests or operations of the Company.

Gifts, Entertainment, Hospitality, and Travel

This Policy allows for normal business hospitality as long as it is reasonable, appropriate, modest, and genuinely corporate in nature. Some examples of acceptable gifts and benefits include:

(a) Token gifts offered in business situations or to all participants and attendees, such as work-related seminars, conferences, trade shows, and business events.

(b) Gifts presented at work-related conferences, seminars, and business events.

(c) Gifts given as a token of gratitude for hosting business events, conferences, or seminars.

(d) Refreshments or meals during meetings or as part of work-related conferences or seminars.

(e) Meals for business purposes.

As a general principle, Associated Persons should not accept or give gifts to third parties with the intention of influencing them to obtain or retain business or in exchange for favors or benefits. Additionally, lavish or unreasonable gifts or hospitality should not be accepted or given, as they may be perceived as attempts by Associated Persons to obtain favorable treatment for personal gain and could raise concerns about improper influence on decision-making. Therefore, the intention behind gifts and hospitality should always be carefully considered.

Associated Persons must ensure that all gifts, entertainment, hospitality, and travel comply with local laws and ethical practices and that the expenses incurred are approved in accordance with the Company’s guidelines.

To prevent any perception of improper conduct or conflicts of interest and to safeguard against the appearance of compromised business judgment, employees should adhere to the following guidelines when deciding whether to accept gifts:

Gifts valued at RM500.00 or above, whether as an individual item or in accumulated value, are expected to be declared.

If circumstances make it impossible, difficult, or impractical to reject a gift, or if rejecting the gift may adversely affect the relationship with customers or business associates, gifts (excluding cash or cash equivalents) may be accepted. If accepted, the gift is considered to have been accepted on behalf of the Company and becomes the property of the Company. The Director will determine the use of the gift.

Consumables such as food gifts and hampers of nominal value do not need to be declared but should be shared among company staff.

Associated Persons should obtain approval from their supervisor for any business entertainment extended. Business meals are generally acceptable.

Business entertainment that may compromise an Associated Person’s ability to perform their duties in a professional manner or create the appearance of impropriety should not be accepted. The following are deemed inappropriate:

(a) Overseas trips in the form of paid holidays or holiday incentives.
(b) Accepting invitations or tickets when the prospective host will not be present at the event with the employee.

If there are doubts regarding whether business entertainment might give rise to conflicts or impropriety, such situations should be referred to the department head and Director for clarification.

Business entertainment valued at RM500.00 or above is expected to be declared.