BookDoc Holdings Sdn. Bhd. (“BHSB”), its subsidiaries and associated company (collectively known as “the Group”) have adopted a zero-tolerance policy against all forms of bribery and corruption. The Group’s Anti-Bribery and Anti-Corruption Policy (“ABCP”) elaborate upon those principles, providing guidance to employees concerning how to deal with improper solicitation, bribery and other corrupt activities and issues that may arise in the course of business.

This ABCP is not intended to provide definitive answers to all questions regarding bribery and corruption. Rather, it is intended to provide employees with a basic introduction to how the Group combats bribery and corruption in furtherance of the Group’s commitment to lawful and ethical behavior at all times. Some of the guidelines are designed to prevent situations in which bribery and corruption practices may take root.

Engaging in bribery or corrupt practices can have severe consequences for you and for the Group. You may face dismissal, fines and imprisonment, and the company may face damage to reputation, financial loss and disbarment from business and other negative consequences.



This ABCP is intended to apply to every BHSB and the Group’s employee and Director (“Stakeholders”). Join venture companies in which the Group does not have a controlling stake or co-venture and associated companies are encouraged to adopt this ABCP or similar principles and standards.

Although this ABCP is specifically written for the Stakeholders, the Group expects that all customers, contractors, sub-contractors, consultants, agents, representatives and other business associates performing work or services for or on behalf of the Group will comply with this ABCP when performing such work or services and all applicable laws and regulations in Malaysia and in all other countries where the Group operates.


If a law conflicts with a policy as set out in this ABCP, you should comply with the law.

If you perceive that a provision in this ABCP conflicts with the law in your jurisdiction, you should consult with your Head of Department or Legal/Compliance Officer, rather than disregard this ABCP without consultation.

If a local custom or policy conflicts with this ABCP, you are called upon to comply with this ABCP. If you have any questions about any of these conflicts, please consult your Head of Department or Legal/Compliance Officer.


References to “you” in this ABCP refer to any person to whom this ABCP applies. Where more specific references are used (such as “employee”), the more specific reference is intended.


This ABCP shall be monitored and reviewed at least once every two (2) years or as and when there are changes in laws and regulations or deemed necessary by the Board of Directors or Management. All Stakeholders shall be informed of any revisions made to this ABCP. The Group reserves the right to vary and/or amend the terms of this ABCP from time to time.


The top level management is primarily responsible for ensuring that the Group:

  1. practices the highest level of integrity and ethics;
  2. complies fully with the applicable laws and regulatory requirements on anti-corruption; and
  3. effectively manages the key corruption risks of the

The top level management must be able to provide assurance to its internal and external stakeholders that the Group is operating in compliance with its policies and any applicable regulatory requirements. This may include establishing the Group’s “tone from the top” (i.e. the Group’s general stance against the use of corrupt practices in relation to its business activities), and spearheading the Group’s efforts to improve upon the effectiveness of its corruption risks management framework, internal control system, review and monitoring, and training and communication.

Thus, for this purpose, the Group should carry out the following:

  1. establish, maintain, and periodically review an anti-corruption compliance programme  which includes clear policies and objectives that adequately address corruption risks;
  2. promote a culture of integrity within the Group;
  3. issue instructions on communicating the Group’s policies and commitments on anti-corruption to both internal and external parties;
  4. encourage the use of any whistleblowing channel in relation to any suspected and/or real corruption incidents or inadequacies in the anti-corruption compliance programme;
  5. assign a Legal/Compliance Officer to be responsible for all anti-corruption compliance matters, including provision of advice and guidance to personnel and business associates in relation to the corruption programme;
  6. ensure that the lines of authority for personnel tasked with responsibility for overseeing the anti-corruption compliance programme are appropriate; and
  7. ensure that the results of any audit, reviews of risk assessment, control measures and performance are reported to all top level management , including the full Board of Directors, and acted upon.

A corruption risk assessment forms the basis of the Group’s anti-corruption efforts. As such, the Group will conduct internal and external corruption risk assessments periodically and when there is a change in law or circumstance of the business. Through a systematic software, the processes of risk evaluation are as follows:

  • Assessment of existing risk by updating its rating of probability and impact;
  • Identify of new risk, if any, and rating of its probability and impact;
  • Assessment/ update of control and management action plan relating to each risk; and
  • Elimination of risk that is no longer

This risk assessment should be used to establish appropriate processes, systems and controls approved by the top level management to mitigate the specific corruption risks the business is exposed to.

For this purpose, the Group will conduct a comprehensive risk assessment at least once a year, with intermittent assessments conducted when necessary. The assessment may include the following:

  1. opportunities for corruption and fraud activities resulting from weaknesses in the Group’s governance framework and internal systems/ procedures;
  2. financial transactions that may disguise corrupt payments;
  3. business activities in countries or sectors that pose a higher corruption risk;
  4. non-compliance of external parties acting on behalf of the Group regarding legal and regulatory requirements related to anti-corruption. Note that, given the wide definition of an associated person, a commercial organisations can be liable for the acts of such third parties; and
  5. relationships with third parties in its supply chain (e.g. agents, vendors, contractors, and suppliers) which are likely to expose the commercial organisation to corruption.


The Group has adopted a “No Gift” Policy whereby, subject only to certain narrow exceptions, the Stakeholders, family members or agents acting for or on behalf of the Stakeholders or their family members are prohibited from, directly or indirectly, receiving or providing gifts.

The Group requires the Stakeholders to abide by this policy to avoid conflict of interest or the appearance of conflict of interest for either party in on-going or potential business dealing between the Group and external parties as a gift can be seen as a bribe that may tarnish Group’s reputation or be in violation of anti-bribery and corruption laws.

A conflict of interest arises in a situation in which an individual is in a position to take advantage of his or her role in the Group for his or her personal benefit, including the benefit of his or her family/household and friends. This would undermine the duties of good faith, fidelity, diligence and integrity as expected by the Group from its employees and Directors in the performance of their duties and obligations.

It is the responsibility of the Stakeholders to inform external parties involved in any business dealings with the Group that the Company practices a “No Gift” Policy and to request the external party’s understanding for and adherence with this policy.


The Group is very much aware that the exchange of gifts can be a very delicate matter where in certain cultures or situations, gift giving is a central part of business etiquette Despite acknowledging the Group’s “No Gift” Policy, some external parties may still insist in providing gifts to the Group’s employees, Directors and/or their family members in certain situations which do not fall within the general exceptions.

Although the general principle is to immediately refuse or return such gifts, accepting a gift on behalf of the Group is allowed only in very limited circumstances as specified in Clause 4.1.3 below whereby refusing the gift is likely to seriously offend and may severe the Group’s business relationship with the third party.

In these limited circumstances, employees are expected to immediately record the gift in the Gift Activity Reporting Form for submission to your Head Of Department who will then decide whether to approve the acceptance of the gift or require it to be returned.

Even if it may appear disrespectful to refuse a gift from an external party, nevertheless, if there is a conflict of interest situation (e.g. bidding is in progress and the company that gave the gift is one of the bidders) then clearly the Head of Department cannot approve the acceptance of said gift (in the case of Directors would advise the same). In this situation, the gift must be politely returned with a note of explanation about the Group’s “No Gift” policy.

In the event the Head of Department approves the acceptance of the gift, he/she must also determine the treatment of the gift whether to:

  1. donate the gift to charity; or
  2. hold it for departmental display; or
  3. share with other employees in the department; or
  4. permit it to be retained by the

In determining the above, Heads of Departments are expected to exercise proper care and judgment in each case, taking into account pertinent circumstances including the character of the gift, its purpose, the position/seniority of the person(s) providing the gift, the business context, reciprocity, applicable laws and cultural norms.


Generally employees are not allowed to provide gifts to third parties.


Although generally the  Group practices a “No Gift” Policy, there  are certain exceptions to the general rule whereby the receiving and provision of gifts are permitted in the following situations:

  1. Exchange of gifts at the company-to-company level (e.g. gifts exchanged between companies aspart of an official company visit/courtesy call and thereafter said gift is treated as company property).
  2. Gifts from the Group to external institutions or individuals in relation to the Group’s official functions, events and celebrations (e.g. commemorative gifts or door gifts offered to all guests attending the event).
  3. Gifts from the Group to the Stakeholders and/or their family members in relation to an internal or externally recognised company function, event and celebration (e.g. in recognition of an employee’s/ Director’s service to the company).
  4. Token gifts of nominal value normally bearing the Group or company’s logo or (e.g. t-shirts, pens, diaries, calendars and other small promotional items) that are given out equally to members of the public, delegates, customers, partners and key stakeholders attending events such as conferences, exhibitions, training, trade shows etc. and deemed as part of the company’s brand building or promotional activities; and
  5. Gifts to external parties who have no business dealings with the Group (e.g. monetary gifts or gifts in-kind to charitable organisations)

Even in the above exceptional circumstances, the Stakeholders are expected to exercise proper judgment in handling gift activities and behave in a manner consistent with the general principles set out below:

  • Conscientiously maintain the highest degree of integrity;
  • Always exercise proper care and judgment ;
  • Avoid conflicts of interest ;
  • Refrain from taking advantage of your position or exercising your authority to further your own personal interest at the expense of the Group; and
  • Comply with applicable laws, regulations and the Group’s policies and



The Group recognises that providing modest entertainment is a legitimate way of building business relationships and as such a common practice within the business environment to foster good business relationship with external clients. As such, eligible employees are allowed to entertain external clients through a reasonable act of hospitality as part of business networking as well as a measure of goodwill towards the recipients.

The Stakeholders should always bear in mind that this is an area where perception is often regarded as more important than facts and therefore you should always exercise proper care and judgment when providing entertainment to third parties especially when it involves public officials to ensure compliance with local anti-bribery and corruption laws.

The Stakeholders are strictly prohibited from providing or offering to provide entertainment with a view to improperly cause undue influence on any party in exchange for some future benefit or result. Any acts of this nature, whether provided directly or indirectly through an intermediary, may be construed as an act of bribery.

You are required to comply with the policies and procedures of HR Department and maintain expenses within the limits of your entitlement, when carrying out entertainment activities.

Any entertainment activities that would involve public officials shall require prior approval from the Head of Department in consultation with HR Department.

Specific rules governing the Stakeholders’ conduct when dealing with Public Officials is set out in greater detail in Part 5 of this ABCP.


The Group recognises that the occasional acceptance of a reasonable and modest level of entertainment provided by third parties in the normal course of business is a legitimate way to network and build good business relationships.

However, it is important for the Stakeholders to exercise proper care and judgment before accepting entertainment offered or provided by a third party. This is not only to safeguard the Group’s reputation, but also to protect the Stakeholders from allegations of impropriety or undue influence.


Corporate hospitality is generally defined as “corporate events or activities organised by an organisation which involves the entertainment of employees and third parties for the benefit of that organisation”. Third parties may include customers, potential customers, contractors external companies and any other stakeholders with whom a business relationship, whether current, prospective or historic exists.

Corporate events and activities include but are not limited to sporting events, gala dinners, concerts or activity based events such as golf tournaments.

Corporate hospitality is recognised as a legitimate way to network and build goodwill in business relationships. However, there is a fine line between what is considered to be legitimate vs. illegitimate forms of corporate hospitality. The question is whether there is any intention to influence or be perceived to influence the improper outcome of a business decision by providing the corporate hospitality.

Corporate hospitality would be illegitimate in the following situations:

  • If it provides an advantage to another person if offered; or
  • If it is given with the intention of inducing the person to perform a relevant function improperly; or
  • If there is knowledge that acceptance of the advantage would in itself be improper

Transparency International has advocated corporate hospitality arrangements/ activities should conform to the following basic principles:

  • Transparency, in that all corporate hospitality is reported and written approval is obtained, all records of which are properly kept ;
  • Proportionality i.e. the corporate hospitality must not be too excessive. In addition, the corporate hospitality must commensurate with the recipient‘s official capacity and not provided in his/her personal capacity;
  • Reasonableness in ensuring that the corporate hospitality is not lavish; and
  • Bona fide, where the intention to offer and/or provide the corporate hospitality is done with good and legal intentions and not convey an expressed or perceived “advantage” or “benefit”, monetart or otherwise, to the individual or entity making or receiving the offer.


The Group recognises that providing corporate hospitality to its stakeholders be it through corporate events, sporting events or other public events, is a legitimate way to network and build goodwill in business relationships.

There may be occasions whereby the Group may issue complimentary invitations in the form of passes, tickets or invitations to its clients, key stakeholders and other third parties to attend events organised or sponsored by the Group or its subsidiaries and other events organised or sponsored by external organisations.

While providing corporate hospitality is a reflection of the Group’s courtesy and goodwill, the respective Heads of Department must exercise proper care to protect the Company’s reputation against any allegations of impropriety or the perception of bribery especially when the arrangements could influence or be perceived to influence the outcome of a business decision and are not reasonable and bona fide expenditures.

There should also be explicit, clear and internally transparent criteria to determine the selection of guests to be invited to the Group’s corporate hospitality event. Reasonable due diligence should be exercised, particularly when the arrangements involve public officials.

There are various local and international anti-bribery and anti-corruption laws that impose strict restrictions on the value and level of entertainment and corporate hospitality to be accorded to third parties, particularly when it is offered to government or public officials.

The Group is committed to comply with applicable laws governing the provision of corporate hospitality to third parties, especially when it involves public officials, and therefore expect employees to undertake the following:

  • to publicise and make clear the Group’s policy on providing and receiving corporate hospitality;
  • to obtain all necessary approvals for the issuance of complimentary tickets or passes to corporate hospitality events;
  • to expressly notify the recipients in writing that all complimentary tickets or passes are NON-TRANSFERABLE (e.g. the terms and conditions for use to be printed on the tickets, passes or invitations). In the event that the recipients are unable to attend, he/she is expected to return the tickets or passes to the

The unauthorised transfer of tickets or passes to persons other than the named recipient may signify to others that the invitation was extended to the recipient in his/her personal capacity.

All expenses incurred to provide the corporate hospitality must be properly documented, receipted and recorded in the Group’s records.


As a general principle, the Group strictly prohibits the Stakeholders from soliciting corporate hospitality nor are they allowed to accept hospitality that is excessive, inappropriate, illegal or given in response to, in anticipation of, or to influence a favourable business decision, particularly from parties engaged in a tender or competitive bidding exercise (for e.g. contractors, vendors, suppliers and etc.).

Notwithstanding the above, the Group recognises that the occasional acceptance of an appropriate level of hospitality given in the normal course of business is usually a legitimate contribution to building good business relationships. However, it is important for the Stakeholders to exercise proper care and judgement before accepting the hospitality.

This is not only to safeguard the Company’s reputation, but also to protect the Stakeholders from allegations of impropriety or undue influence. If you have any doubts on the appropriateness of a corporate hospitality offered by an external party for e.g. a contractor or supplier, you should either decline the offer or consult your Head of Department or Legal/Compliance Officer.



A “public or government official” is includes, without limitation, candidates for public office, officials of any political party, and officials of state-owned enterprises.

A high degree of caution and diligence must be exercised when dealing and interaction with public officials as the laws of bribery and corruption in some countries are more stringent and provides for stricter punishments. Providing gift, entertainment or corporate hospitality to public officials or their family/household members is generally considered a “red-flag” situation in most jurisdictions.

You are prohibited from paying for, on behalf of or to benefit of the Group and/or any of the Stakeholders for non-business travel and hospitality for any public official or his/her family/household members without permission from your Head of Department in consultation with either HR Department or Legal/Compliance Officer.

If approval is obtained for you to provide gift, entertainment or corporate hospitality to public officials, you must ensure that the gift, entertainment or corporate hospitality is not excessive and lavish, and must commensurate with the official designation of the public official and not his personal capacity. You must also be aware of local laws governing the activity and to ensure compliance. You should seek guidance from either HR Department or Legal/Compliance Officer prior to providing any gift, entertainment or corporate hospitality to public officials.


As a responsible corporate citizen, the Group is committed to cultivating a strong relationship with the local communities in which we live and work by contributing to the well-being of the people and the nation. It is however important that all Corporate Social Responsibility (“CSR”), sponsorships and donations are made in accordance with the Group’s policies and receive prior authorisation from the Group’s Management or the Board where applicable.


As part of our commitment to CSR and sustainable development, as a general matter, the Group provides such assistance in appropriate circumstances and in an appropriate manner. However, such requests must be carefully examined for legitimacy and genuineness in not being carried out to improperly influence a business outcome.

The proposed recipient must be a legitimate organisation and the rightful recipient. Therefore, appropriate due diligence must be conducted in particular to ascertain whether any public officials are affiliated with the organisation. There should be a transparent selection and decision-making process, with proper records kept.

Any red-flags must be resolved before committing any funds to the programme. Even requests determined to be legitimate must be carefully structured to ensure that the benefits reach their intended recipients.


All employees must ensure that all sponsorships and donations are not used as a subterfuge for bribery or used to circumvent including in particular, the prohibition on bribery.

The Group needs to be certain that donations to foreign-based charities or beneficiaries are not made to secure any improper advantage or retain any business relationship, disguised illegal payments to public officials, and must ensure that the charity does not act as a conduit to fund illegal activities in violation of international anti-money laundering, anti-terrorism and other applicable laws.

In accordance with the Group’s commitment to contribute to the community coupled with its values of integrity and transparency, all sponsorships and donations must comply with the following:

  • ensure such contributions are allowed by applicable laws;
  • obtain all the necessary internal and external authorisations;
  • be made to well established entities having an adequate organisational structure to guarantee proper administration of the funds;
  • be accurately stated in the company’s accounting books and records; and
  • not to be used as a means to cover up an undue payment or bribery.

Examples of red-flags to look out for are as follows:

  • The proposed recipient/ organisation has affiliations with a Public Official or their relatives are involved;
  • The contribution is made on behalf of a Public Official;
  • There is a risk of a perceived improper advantage for the Group; and
  • The proposed recipient is based in a high risk country, the request comes from a high risk country or the activity takes place in a high risk country.

The Group requires employees to use good judgment and perform reasonable due diligence in assessing the requests.


Before making a commitment to a CSR activity, sponsorship or donation requested by external stakeholders, you must first conduct proper due diligence to ensure that the requests are legitimate and that any red-flags raised are resolved prior to committing the funds.

The request is evaluated against the Group’s guidelines on CSR, sponsorships and donations and meets the following criteria:

  • There is no risk of a perceived improper advantage for the Group;
  • The proposed recipient is a legitimate organisation and proper due diligence are made/ background checks/ reputation or status of the recipient/organisation; and
  • The proposed recipient/ organisation does not have affiliations with a Public Official

If the request meets the above requirements and it is reasonably ascertained to be legitimate in nature, you can proceed to prepare a recommendation/memorandum seeking Management’s approval.


As a matter of general policy, the Group does not make or offer monetary or in-kind political contributions to political parties, political party officials or candidates for political office.

If any contribution is made, it must be permissible under applicable laws and must not be made with any promise or expectation of favourable treatment in return and must be accurately reflected in the Group’s records.

Good faith payments to a government entity such as payments to the host country’s federal treasury required by contract or law, are not prohibited, so long as they are made with due care to the government entity and not to any individual official.

The Group encourages employees to participate in the political election process by voting. Employees may choose to make personal political contributions as appropriate within the limits established by law. Under no circumstances, however, will any employee be compensated or reimbursed in any way by the Group for any personal political contribution.



Facilitation payment is payments made to secure or expedite the performance by a person performing a routine or administrative duty or function. Offering, promising or requesting facilitation payments is just as prohibited as actually paying or receiving facilitation payments. Facilitation payments need not involve cash or other financial asset; it can be any sort of advantage with the intention to influence them in their duties.

The Group prohibits accepting or obtaining, either directly or indirectly, facilitation payments from any person for the benefit of the employee himself or for any other person. The reason underlying this prohibition is that facilitation payment is seen as a form of bribery and corruption.

All persons must not offer, promise, give, request, solicit, accept, agree to accept or receive anything which might reasonably be regarded as a facilitation payment. If you receive a request or if you are offered facilitation payments, you must report it to your Head of Department.


However, there are certain situations or circumstances where you are faced with having to make facilitation payments under duress or coercion, including life threatening and actual or potential loss of life limb or liberty or of the company’s employees. In dangerous situations like this, you are allowed to make payments but you must immediately report to your Head of Department and appropriate document(s) of such incident along with the reasons must be recorded. Making facilitation payment in such a situation is the only exception which can be used as a defence when faced with allegations of bribery and corruption.



The Group’s dealings with third parties, which include customers, contractors, suppliers, agents, consultants, joint venture partners, introducers/government intermediaries etc., must be carried out in compliance with all relevant laws. As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated.

The Group expects that all third parties acting for or on its behalf to share the Group’s values and ethical standards as their actions can implicate the Group legally and tarnish its reputation. Therefore, where we engage third parties, such as contractors, agents, intermediaries or joint venture partners, we are obligated to conduct appropriate counterparty due diligence to understand the business and background of the prospective business counterparties before entering into any arrangements with them to ensure that we are dealing with counterparties that subscribe to acceptable standard of integrity in the conduct of their business.

To help ensure that we only do business with third parties that share the Group’s standards of integrity, we must do the following:

  • Conduct due diligence to assess the integrity of the Group’s prospective business counter parties. Do not enter into any business dealings with any third party reasonably suspected of engaging in bribery and improper business practices unless those suspicions are investigated and resolved;
  • All third parties are made aware of the ABCP and our expectations of them by way of their declaration form; and
  • Continue to be aware of and to periodically monitor third party performance and business practices to ensure ongoing

If at any point during the due diligence exercise or in the dealings with a third party, there are conflicts of interest or red-flags, as per Section 11, are raised, these warrant further investigation and must be sufficiently addressed before the engagement of the third party can progress.

The Group requires its employees to use good judgment and common sense in assessing the integrity and ethical business practices of third parties and have provided the above as a guideline.


The Group is committed to uphold the highest standard of ethics and integrity in all aspects of its procurement and sales activities. The Group should avoid dealing with any contractors, suppliers, customers or business associates known or reasonably suspected of corrupt practices or known or reasonably suspected to pay bribes.

The Group must ensure that all procurement and sales activities are in line with the procurement and sales policies and procedures that are applicable in the jurisdiction, which include:

  • Due diligence of contractors, suppliers, customers and business associates are undertaken before they dealt with the Group;
  • Contractors, suppliers, customers and business associates are made aware of and understand the this ABCP and that they will comply accordingly;
  • All commercial contracts and invitations to bid incorporate the provisions relating to business conduct, conflict of interest and fighting corruption and unethical practices; and
  • All commercial contracts with major contractors, suppliers, customers and business associates to incorporate a provision where the Group retains the right to audit third party compliance with this ABCP

The Group must conduct due diligence on prospective contractors, suppliers, customers and business associates to confirm whether or not these external parties have in place anti-bribery programmes and that they will not engage in any improper practices. The scope and extent of the due diligence required will vary depending upon the circumstances of each proposed transaction.

Screening should be conducted on the company, its directors and top management and this can be done through the due diligence process and procedures.

The Group should also monitor significant contractors, suppliers, customers and business associates as part of their regular review of the performance of the third parties. The Group has the right to terminate their services in the event that these third parties pay bribes or act in a manner which is inconsistent with this ABCP.

If any red-flags are raised, these issues must be resolved. If it is not possible then the company must be barred from being on the list of registered contractors /suppliers/customers/business associates and/or disqualified from participating in any the Group’s business dealings.


The Group in particular, the procurement function must follow the following procedures when dealing with contractors, suppliers, customers and business associates:

  • Perform a risk assessment using a risk-based approach;
  • Undertake due diligence on the third party depending on the level established by the risk analysis; and
  • Preparing and maintaining appropriate written documentation of the due diligence and risk assessment

What to look for in anti-bribery due diligence:

  • Has bribery taken place historically?
  • Is it possible or likely that bribery is currently taking place?
  • If so, how widespread is it likely to be?
  • What is the commitment of the board and top management of the target to countering bribery?
  • Does the target have in place an adequate anti-bribery programme to prevent bribery?
  • What would the likely impact be if bribery, historical or current, were discovered after the transaction had completed?

The Group provides equal opportunity for any qualified and competent individual to be employed by the company from various multicultural and multiracial background.

The recruitment of employees should be based on approved selection criteria to ensure that only the most qualified and suitable individuals are employed. This is crucial to ensure that no element of corruption is involved in the hiring of employees.

In line with this, proper background checks should be conducted in order to ensure that the potential employee has not been convicted in any bribery or corruption cases nationally or internationally. More detailed background checks should be taken when hiring employees that would be responsible in management positions, as they would be tasked with decision-making obligations.

If you find or suspect that another person subject to this policy has violated or about to violate this policy or applicable law, whether deliberately or inadvertently, you must forthwith report the same, in writing, to your Head of Department or HR Department.


During transaction or business arrangement, you are expected to ask question and look out for corruption and bribery “red flags”. If you are unsure of the next course of action, you should consult the Legal/Compliance Officer and should not ignore the red flags. Transaction may not proceed if there are “red flags” yet to be resolved.

Examples of “red flags” include but not limited to the followings:

  1. The other party has a reputation or history of bribery;
  2. Excessive reliance on third-party agents or “middleman”;
  3. Unusual payment terms, such as large upfront payment or via agents;
  4. Large amount of cash payment;
  5. Payments to private account or offshore bank account;
  6. Large charity contribution or sponsorship;
  7. Gifts– lavishness, secrecy, inaccurate records;
  8. Request for invoice with amount differ from the payment;
  9. The other party refuses to disclose its owners, partners or principals;
  10. The other party refuses to sign conflict of interest declaration or disclose any connection with public officer;
  11. Objection to anti-bribery representations and warranties in commercial agreements or negative response when told of such requirements;
  12. The transaction involves a country known for a high incidence of corrupt payments; and
  13. Family, business or other “special” ties with government or public

The Group encourages honesty, fairness, openness and transparency in its commitment to the highest standard of integrity and accountability.

If you make a report or disclosure about any actual or perceived bribery or corruption in good faith, belief, without malicious intent, that a breach or violation as aforesaid may have occurred or may about to occur, you will be accorded protection of confidentiality, to the extent reasonably practicable, notwithstanding that, after investigation, it is shown that you were mistaken. In addition, employees who whistleblow internally will be also be protected against detrimental action for having made the disclosure, to the extent reasonably practicable.

Any alleged or suspected improper conduct must be disclosed using the procedures provided for in the Group’s Whistleblowing Policy


The top level management shall ensure that regular reviews are conducted to assess the performance, efficiency and effectiveness of the anti-corruption programme, and ensure the programme is enforced. Such reviews may take the form of an internal audit, or an audit carried out by an external party.

The reviews should form the basis of any efforts to improve the existing anti-bribery and anti-corruption controls in place in the Group.

For this purpose, the Group will implement the following:

  1. plan, establish, implement and maintain a monitoring programme, which covers the scope, frequency, and methods for review;
  2. identify the competent person(s) and/or establish a compliance function to perform the monitoring programme, in relation to the Group’s anti-corruption measures;
  3. conduct continual evaluations and improvements on the Group’s policies and procedures in
    lation to corruption;
  4. monitor the performance of personnel in relation to any anti-corruption policies and procedures to ensure their understanding and compliance with the Group’s stance in their respective roles and functions;
  5. conduct disciplinary proceedings against personnel found to be non-compliant to the programme; and
  6. consider an external audit (for example MS ISO 37001 auditors) by a qualified and independent third party at least once every three years to obtain assurance that the Group is operating in compliance with its policies and procedures in relation to corruption.

The commercial organisation should develop and disseminate internal and external training and communications relevant to its anti-corruption management system, in proportion to its operation, covering the following areas:

  1. policy and procedures;
  2. training;
  3. reporting channel; and
  4. consequences of non-compliance.

Communication of Policies
This ABCP is made available to public, and will be appropriately communicated to all personnel and business associates. When planning strategies for communicating the Group’s position on anti-corruption, the Group will take into account what key points should be communicated, to whom they should be communicated, how they will be communicated, and the timeframe for conducting the communication plan. The Group also will consider what languages the materials will be communicated in.

The communication of the Group‘s policy may be conducted in a variety of formats and mediums.
These may include, but are not limited to:

  1. messages on the Group’s intranet or website;
  2. emails, newsletters, posters;
  3. code of business conduct and employee’s handbooks;
  4. video seminars or messages; and
  5. town-hall

The Group will provide its employees and business associates with adequate training to ensure their thorough understanding of the Group’s anti-corruption position, especially in relation to their role within or outside the Group.

The training may be conducted in a variety of formats, including but not limited to:

  1. induction programs featuring anti-corruption elements;
  2. role-specific training, which is tailored to corruption risks the position is exposed to;
  3. corporate training programs, seminars, videos and in-house courses;
  4. intranet or web-based programs;
  5. town hall sessions;
  6. retreats; and
  7. out-reach programs.

Failure to comply with this ABCP may result in severe consequences, which could include internal disciplinary action or instant dismissal if you is found liable (guilty) in a domestic inquiry. Violation of this ABCP may also constitute a criminal offence. If it appears in the opinion of the Board that any director, officer, employee, consultant or contractor of the Group may have violated such laws, then the Group may refer the matter to the appropriate enforcement authorities, which could lead to civil or criminal penalties for the Group and/or the responsible person. Under the Malaysian Anti- Corruption Commission Act 2009 (“MACC Act”), the person participates in bribery and corruption may be subject to imprisonment up to 20 years and a fine of not less than ten times the sum or value of the relevant bribe (gratification) or RM1,000,000.00, whichever is higher (no upper limit).


The Group reserve the right to amend, modify or discontinue this ABCP at any time, for any reason.