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ANTI-CORRUPTION POLICY


1. Introduction


1.1 Integrity is a core value and guiding principle in decisions and actions in the workplace. A1 Consuting is committed to conducting business in a fair, open, honest and transparent manner. All work performed must comply with the highest ethical standards.


1.2 Bribery and corruption undermine business ethics and damage the reputation of an organization. Therefore, the Company firmly opposes any inappropriate or illegal behavior that affects transparent business.


1.3 The Anti-Corruption Policy clearly defines the conduct that the Company expects from employees. This policy also applies to any third party performing services for the Company and on behalf of the Company.

2. Objectives


2.1 The Company’s management is committed to complying with the Anti-Corruption Law in Malaysia and all countries in which the Company operates. Therefore, this Anti-Corruption Policy has been developed to meet the above legal and regulatory requirements; and setting out the Company’s overall position on bribery and corruption in all its forms, such as negotiating with third parties, managing conflicts of interest, gifts, hospitality and whistleblowing.


2.2 The overriding objective of this Anti-Corruption Policy is to provide guidance and support to the Company’s employees and business partners in identifying and responding to bribery and corruption issues, as well as understanding their roles and responsibilities.


2.3 This Anti-Corruption Policy should also be read in conjunction with other relevant policies and regulations, such as the Anti-Bribery and Corruption Framework, Employee Handbook, Code of Conduct and Ethics, Whistleblowing Policy and Anti-Corruption Guide.

3. Scope


This Anti-Corruption Policy applies to:


(a) directors (both executive and non-executive), managers, employees of the Company (including permanent, temporary and contract (limited-term) employees), and volunteers (collectively, “Employees”).


(b) any third party (individual or entity) performing services for or on behalf of the Company. This includes current and potential customers, joint ventures, joint venture partners, contractors, consultants, subcontractors, suppliers, agents, distributors, representatives, intermediaries and investors (collectively, “Business Partners”)


(c) joint ventures in which the Company has a non-controlling interest, joint ventures and affiliates are encouraged to adopt these or similar principles.

4. Definitions


In this Anti-Corruption Policy:


(a) Bribery means the act of giving a “benefit” in exchange for some kind of influence or reciprocal action, which the recipient would not have received.


(b) Company means A1 Consulting Sdn. Bhd. (A1 Consulting) (Enterprise Registration Number: 202401006652).


(c) Corruption is the abuse of personal power for personal gain. Essentially, it is the act of accepting any benefit or reward in the form of cash or high-value goods, in order to perform a task related to the individual’s work.


(d) Facilitation fee is a payment or other provision made to or received by an individual from a third party to control a process or decision, to secure or carry out a routine administrative task or function.


(e) Benefit is understood as ‘something of value’, including but not limited to money, charity, gift, loan, fee, reward, securities, information, property or interest in property, employment, appointment, issue, forbearance, assignment, promise, discount, rebate, employment service or employment contract or service and agreement to provide employment or provide services in any capacity.


(f) Human Resources Department in this policy refers to the Human Resources Department of the Company.


(g) Risk Management Officer in this policy refers to the Risk Management Officer of the Company.

5. Anti-Corruption Statement


5.1 The Company has a zero-tolerance approach to all forms of bribery and corruption and will conduct the business activities ethically, honestly and with high standards of integrity. This applies to the Company’s business activities in all countries around the world.


5.2 The provisions of this Anti-Corruption Policy are based on legal requirements and therefore, breaches of this policy may subject individuals and the Company to sanctions, including fines and imprisonment. Such breaches may also seriously damage the reputation of the Company and Employees. Therefore, Employees and Business Partners must not, directly or indirectly, offer, give, receive, or solicit anything of value with the intent to unlawfully influence the decisions or actions of a trusted individual within an organization, regardless of whether it benefits the company or those involved in the transaction.


5.3 The Anti-Corruption Policy applies equally to the Company’s business dealings with state (public sector) and commercial (private sector) entities, and includes directors, employees, agents, consultants, representatives of the above entities and other designated representatives such as civil servants, politicians and public authorities.


5.4 The Company will also conduct due diligence on all Employees (including prospective Employees), Business Partners, major business projects and activities including charities and sponsorships, especially those with a high risk of bribery and corruption in accordance with this Anti-Corruption Policy.


5.5 The Company encourages Employees and Business Partners to report all suspected or attempted violations of the Bribery and Corruption Law and prohibits retaliation against those who report in good faith. The Company will ensure that Employees are not penalized or retaliated against for refusing to pay or accept bribes or for refusing to engage in illegal conduct.

6. Anti-Corruption Principles


6.1 Conflicts of Interest


6.1.1 Conflicts of interest may occur when Employees participate in external business activities or develop personal interests that benefit themselves or closely related individuals (e.g., relatives or close partners) in a way that competes with or conflicts with the Company's interests.


6.1.2 Employees must obtain written approval from the head of the Company before undertaking activities that may give rise to conflicts of interest.


6.1.3 Regular conflict declarations are required for all employees. In addition, employees must make additional declarations as soon as conflicts of interest arise.


6.2 Gifts and Hospitality


6.2.1 In general, Employees may accept or offer gifts and hospitality ONLY if:


(i) The gifts are infrequent;


(ii) The gifts are reasonable and not of excessive value;


(iii) The gifts do not improperly influence or pose a risk of improperly influencing a decision


6.2.2 In addition to the above provisions, any acceptance or offer of gifts and hospitality must be subject to the authority limits set out in the Anti-Corruption Policy Guide.


6.2.3 Accepting gifts and hospitality


(a) It is permissible to accept gifts and hospitality, provided that the gifts and hospitality are of modest value and appropriate to the situation/rank. Employees should not accept any gift or hospitality that could be construed as a reward, inducement or other corrupt practice.


(b) However, in all cases, Employees or their immediate family members, such as spouses, family members, relatives or close colleagues, are STRICTLY PROHIBITED from accepting gifts in the form of cash or cash equivalents (including gift certificates, loans, commissions, coupons, discounts or any other related form), unless it is part of a routine practice and this should be limited to a nominal value and reported to A1 Consulting’s Risk Management Officers, Human Resources and Risk Management Director.


(c) Examples of acceptable gifts and hospitality are as follows:


  • Gifts: corporate promotions, seasonal or festive gifts.
  • Hospitality: Beverages (tea/coffee) or lunch during the working day, not exceeding the frequency specified in the Anti-Corruption Guidelines.


6.2.4 Gifts and hospitality


(a) Employees shall not offer or give gifts or hospitality if they know or suspect that it would violate the rules of the recipient’s organization or be contrary to local law.


(b) The Company may offer corporate gifts, i.e. products bearing the Company’s logo/identity for advertising/branding/marketing purposes. Any gift or hospitality must be approved by the authority specified in the Anti-Corruption Guidelines and must meet the following conditions:


  • The gift or hospitality must be limited, customary and appropriate in all circumstances;
  • The gift or hospitality does not have or should be perceived to have any influence on work or decisions;
  • No specific or improper benefit is expected from the recipient;
  • The gift is given independently and does not influence the recipient’s business judgment;
  • The donor does not intend to defraud or commit a crime through the gift; and
  • The gift and hospitality is conducted in a clear and transparent manner.


(c) A Company's employee must be present (as the host) at the reception. Otherwise, the expenditure will be treated as a gift.


6.2.5 For further information on managing gifts and hospitality, please refer to the Anti-Corruption Guidelines.

6.3 Entertainment


6.3.1 Entertainment may be considered a bribe if it is made with the intention of influencing someone to do something wrong, or as a reward for doing something wrong. Employees are permitted to offer or accept entertainment, provided that it is for a reasonable reason and within the limits of authority specified in the Anti-Corruption Guidelines.


6.3.2 Employees are PROHIBITED from paying or participating in any entertainment that is excessively expensive, illegal, unethical, wasteful/extravagant, unrelated to the business of the company, or that involves business partners (including potential business partners) in the procurement process that may cause the company to be disadvantaged or have a negative impact.


6.3.3 Entertainment only applies to individuals for legitimate business purposes. The Company will not make payments or reimburse expenses to persons related to the above individual, such as spouses, family members, relatives or close associates, without a legitimate business purpose with the Company.


6.4 Donations and Sponsorships


6.4.1 The Company permits charitable donations and sponsorships for legitimate reasons and in accordance with applicable laws and regulations. However, the Company STRICTLY PROHIBITS the giving and receiving of donations and sponsorships that influence business decisions.


6.4.2 All requests for charitable donations and sponsorships must be regularly reviewed and subject to the authority limits specified in the Anti-Corruption Guidelines.


6.5 Political Contributions


6.5.1 In general, the Company DOES NOT make or make political contributions in cash or in kind to any political party, political official or candidate running for office.


6.5.2 The Company shall ONLY make political contributions where such contributions are permitted under applicable law. The authority to approve political contributions rests with the A1 Consulting board of directors.


6.5.3 The Company shall NOT make any political contributions for the purpose of maintaining business or providing benefits to the Company.


6.6 Facilitation Payments


6.6.1 Facilitation payments are illegal. Therefore, the Company prohibits Employees or Business Partners from offering, soliciting, or promising facilitation payments of any kind on behalf of the Company. Employees are also prohibited from accepting or demanding such facilitation payments, whether in cash or in kind.


6.7 Recruitment, Promotion, or Support of Employees


6.7.1 The recruitment, training, performance appraisal, compensation, recognition, and promotion of employees shall be planned and updated regularly and with integrity. The Company will not recruit candidates who have improperly benefited the Company while working for previous organizations.


6.8 Business Partners

6.8.1 The Company is committed to conducting business in a fair, transparent and ethical manner. The Company will only conduct business with businesses or individuals who share the same values ​​and will uphold the Company's principles of applying ethical standards to business transactions.

7. Anti-Corruption Compliance

7.1 The Company shall maintain an independent anti-corruption compliance function through the Risk Officer and the Human Resources Department, in coordination with A1 Consulting's Risk and Integrity Management Department, to oversee the planning, implementation, management and improvement of the Company's anti-bribery and corruption policies and procedures.


8. Training and Awareness


8.1 The Company shall conduct awareness-raising programs for all Employees on integrity and ethics, anti-corruption situations and practices.


8.2 Training shall be conducted on a regular basis, appropriate to the level of risk of corruption associated with the situations and departments.


9. Reporting


9.1 The Company strongly encourages employees to report bribery and corruption cases that have occurred or suspected cases of corruption without fear of retaliation or retaliation.


9.2 The Company has established a process for reporting corruption and other forms of misconduct, including violations of this Anti-Corruption Policy, through established, confidential channels that are accessible to all Employees and external parties including Business Partners. Details of the whistleblowing process are set out in the Company's Whistleblowing Policy.


9.3 The Company requires all employees to commit to complying with this policy. The Company will ensure that whistleblowers will not be retaliated against, harassed or harmed in any way, provided the report is truthful (i.e. the report is not malicious and is not unfounded and is not intended to cause harm to another person or organization). The individual will still be protected if a subsequent investigation reveals that the whistleblower was mistaken about the relevant facts, rules and procedures.


10. Records


10.1 The Company will maintain accurate and detailed records and relevant records; and will have appropriate internal controls to evidence all payments made. The Company will report and maintain records of the amount and reasons for gifts, hospitality and entertainment received and given, including donations, sponsorships and similar expenses, and such expenses will be subject to management review.


11. Monitoring and Supervision


11.1 The Risk Management Officer and the Human Resources Department are responsible for monitoring the adequacy and effectiveness of the application of this Policy and regularly reviewing its implementation, including assessing its suitability, adequacy and effectiveness.


11.2 Internal control systems and procedures designed to prevent corruption must be regularly tested to ensure that they are effective.


11.3 The Company may amend this Anti-Corruption Policy at any time to improve its effectiveness in combating corruption.


12. Non-compliance


12.1 Corruption is considered a serious matter and the Company will apply sanctions in the event of non-compliance with this policy. Employees who fail to comply with this policy will be subject to disciplinary action, up to and including dismissal.


12.2 For Business Partners and external agencies, non-compliance may result in sanctions, up to and including termination of contracts. In the event that the Company's interests have been affected by non-compliance by individuals and organizations, the Company will apply higher legal actions to handle the violation.


13. Ownership


13.1 This Anti-Corruption Policy is owned by the Company. Any feedback or requests regarding the provisions of this policy should be directed to the Risk Management Officer and Human Resources Department or the Risk Management Director of A1 Consulting.