Introduction
The Group takes a zero-tolerance approach to corruption and bribery and is committed to conduct its business with the highest standard of openness, integrity, honesty and accountability.
Corruption and bribery are criminal offences and penalties upon conviction will be fines and/or imprisonment and will cause serious damage to our reputation.
Purpose, scope and responsibility
The purpose of this policy is to:
- establish principles that governs our conduct in upholding the Group’s position on corruption and bribery;
- reinforce our intention and obligation to act honestly and ethically in all our business dealings; and
- provide information and guidance to the Group to recognize and deal with corruption and bribery issues.
This policy applies to all subsidiaries of the Group including those working with the Group ie. suppliers, customers, sub-contractors, consultants, agents and any third party associated with the Group.
The Board of Directors has oversight of this Policy and the Executive Directors are responsible for ensuring the compliance with this Policy. Every employee is required to be familiar with and to comply with this Policy.
Policy statement
Bribery and corruption are not only against our Group values; they are illegal and can expose both the employee and the Group to fines and penalties, including imprisonment and reputational damage.
The Group will not seek to influence others, either directly or indirectly, by offering, paying or receiving bribes or kickbacks or facilitation payments, or by any other means that is considered unethical, illegal or harmful to our reputation for honesty and integrity.
Employees of the Group are expected to decline any opportunity which would place our ethical principles and reputation at risk.
The Group will not engage third party to give or receive a bribe. A third party includes, but is not limited to consultants, agents, representatives and subcontractors.
Definition of bribery and corruption
Bribery is offering or giving anything of value with the intention of inducing a person to act or to reward a person for having acted in order to gain or retain business advantage. ‘Anything of value’ includes, but is not limited to cash, cash equivalents (such as gift cards/vouchers), entertainment, travel packages and etc.
Corruption is a dishonest or fraudulent conduct by those in power (private or government) for private gain.
Gifts, Entertainment and Hospitality
The Group encourage the use of good judgment, discretion, and moderation when giving or accepting gifts or entertainment in business dealings. Gifts and entertainment given or received must be in compliance with local law, must not violate the giver’s and/or receiver’s policies on the matter, and be consistent with local custom and practice.
We do not solicit gifts, entertainment, or favors of any value from persons or companies with which the Group does business. We will not act in a manner that would place any vendor or customer in a position where they may feel obligated to make a gift, provide entertainment, or provide personal favors to do business or continue to do business with the Group.
All benefits (including gifts and entertainment) must be reasonable in value, infrequent in nature, transparent and open and not given to influence or obtain an unfair advantage.
Facilitation payments and kickbacks
We do not make, and will not accept, facilitation payments or kickbacks of any kind.
Facilitation payments refers to small sum, unofficial payment made to secure or expedite a routine procedure whereas kickbacks refer to the return of a sum already paid or due as a reward for awarding of business to certain parties or business partners.
Donations and Political Contribution
The Group does not make charitable donations or contributions to political parties. Whilst employees are permitted to make personal political contributions, the Group will not make any reimbursement for these personal political contributions back to its employees.
Contributions or donations made by the Group to community projects or charities need to be made in good faith and in compliance with this Anti-Corruption and Bribery Policy.
Reporting violations
If any employee has been offered a bribe from a person or business partners of the Group or the employee has been offered something of value and are uncertain whether the employee can accept it, the employee should report the matter immediately.
Any employees with any suspicions, concerns or queries regarding any improper business practices, the employee should raise these matters to the HR Manager who will pass this information to the Executive Director or an investigating officer nominated by the Executive Director.
Our Whistleblowing Policy protects employees who report concerns in good faith. Details of our Whistleblowing Policy can be obtained from our website.