M+ Online

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1. POLICY STATEMENT

  • The Company practices a ‘Zero Tolerance’ policy against all forms of bribery and corruption. Employees and Business Associates MUST NOT offer, promise or give a bribe to anyone, and MUST NOT request, agree to accept or take a bribe from anyone. Bribery is a crime and penalties can be prison sentences and face heavy financial penalties.

    Employees are reminded that they will be subject to strict disciplinary action, including dismissal as well as civil and criminal liability if he/she is found in violation of this policy.

  • The Company is committed to take all necessary measures to ensure that our businesses do not participate in any corrupt activities and to implement adequate procedures effectively to comply with the provisions of Section 17A of the amended MACC Act 2009.

2. GIFTS, ENTERTAINMENT AND HOSPITALITY

  • The Company has adopted a “NO GIFT” Policy whereby employees are prohibited from, directly or indirectly, receiving or providing gifts they may be seen or interpreted as bribes that may tarnish its reputation or be in violation of anti-bribery and corruption laws.

    However, the company recognises that the exchange of business courtesies, such as modest gifts, hospitality and entertainment (including meals, invitations to attend promotional events or parties) particularly during festive periods is customary and legitimate to create goodwill, and/or strengthen business and commercial relationships. Such courtesies are allowed but they must not exceed the value of RM500 per occasion, per event or per gift.

  • When unsure, Employees and Associate should consult his/her Line Manager or Executive Director or Managing Director as applicable.

3. DONATIONS, SPONSORSHIP & CORPORATE RESPONSIBILITY (CSR)

  • 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;
    • not to be used as a means to cover up an illegal payment or bribery.

4. FACILITATION PAYMENTS & KICKBACKS

All Employees are reminded that offering and/or receiving “facilitation payments” / “kickback” is a major misconduct.

5. MONEY LAUNDERING

  • The Company strongly objects to practices related to money laundering, including dealing in the proceeds of criminal activities.
  • To avoid violating anti-money laundering laws, Employees are expected to always conduct customers and counterparty due diligence to understand the business and background of Company prospective business customers and counterparties and to determine the origin and destination of money, property and services.

6. POLITICAL CONTRIBUTIONS

  • As a matter of general policy, Company 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 company's accounting records. Under no circumstances, however, will any employee be compensated or reimbursed in any way by the Company for a personal political contribution.

7. DEALING WITH PUBLIC OFFICIALS

Employees are prohibited from providing gifts, entertainment or hospitality to public officials or their family/household members in exchange for future benefits or results. Due diligence must be carried out to confirm that the Public Official is the appropriate person based on his/her official position. Proper care and judgment must be exercised to confirm that there is no conflict of interest when dealing with public officials.

8. WHISTLEBLOWING POLICY: RAISING A CONCERN OR COMPLAINT

  • Our success in combating all forms of bribery and corruption hinges on our personal commitment to adhere to this Policy. Therefore, it is our responsibility to promptly report any suspected contraventions of this Policy.
  • If you have any suspicions or concerns regarding conduct to which this Policy applies, or if you become aware of any action in conflict with this Policy, you must report those concerns or actions to your Line Manager, Human Resources or report your concerns, confidentially, by following the procedure set out in the Whistleblowing Policy and Procedures made available via the Company’s website.
  • Any Employee who fails to report known or suspected violations may be subject to disciplinary action including termination of employment. In Malaysia, any person who knows and fails to report an act of giving and offering of bribes Is committing an offence under Section 25(1) and (2) of the MACC Act 2009.
  • Any report made in accordance with Section 12.2 will be treated with utmost confidentiality. No Employee or Associate acting in good faith will suffer adverse consequences to his employment or retaliation for reporting or for refusing to engage in prohibited conduct, even if such refusal results in loss of business opportunities to the Company or the Group.
  • If you believe that you have suffered and detrimental treatment as a result of refusing to take part in bribery or because of reporting concerns under this policy in good faith, you should raise the matter by following the procedure set out in the Whistleblowing Policy and Procedures made available via the Company’s website.

9. TRAINING & COMMUNICATIONS

  • Employees will be provided with regular anti-corruption compliance training programmes to educate them about the requirements and obligations of anti-bribery and corruption laws and this Policy.
  • For successful compliance of this policy, Top Management will be responsible to ensure continuous efforts to communicate, train and educate all Employees and associates.
  • Records pertaining to training, education and communication programmes of Employees and associates are kept and maintained by the Top Management and Line Manager for reference.

10. RESPONSIBILITY FOR THE POLICY

  • This Policy is reviewed and approved by the Board of Directors and oversight of this Policy has been delegated to the Executive Director or in his/her absence, Managing Director, which monitors the effectiveness of and compliance with this Policy.
  • The Board of Directors, the Executive Director, Managing Director and the Top Management set the tone at the top providing leadership and support for the Policy and taking responsibility for its effectiveness units. Each Line Manager is responsible for the implementation and all communication and training activities to ensure every employee understood and complied with this Policy.