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ANTI-BRIBERY & ANTI-CORRUPTION POLICY
 

Investor Relations | Corporate Governance | Anti-Bribery & Anti-Corruption Policy

 

   
     
 
 
 
   
 
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INTRODUCTION  

The EP Manufacturing Bhd ("EPMB") Group has adopted a zero tolerance policy against all forms of bribery and corruption. The EPMB Anti-Bribery and Corruption Policy (hereinafter referred to as the ("Policy") 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. It is also intended to apply to every director (executive and non-executive) except as otherwise stated in this Policy.

The Policy are not intended to provide definitive answers to all questions regarding bribery and corruption. Rather, they are intended to provide employees with a basic introduction to how EPMB combats bribery and corruption in furtherance of the group's commitment to lawful and ethical behavior at all times.

 
   
OBJECTIVES  
  1. To set out the responsibilities of those working for EPMB, in observing and upholding EPMB¡¯s position on bribery and corruption;
  2. To provide information and guidance to those working for EPMB on how to recognise and deal with potential bribery and corruption issues;
  3. To ensure that the Company has adequate procedures in place to prevent and detect bribery and corruption; and
  4. To protect the Company against the possible penalties and repercussions resulting from acts of bribery and corruption or being associated with such behaviour resulting from acts of bribery and corruption or being associated with such behaviour.
 
   

SCOPE OF POLICY

 

The principles and obligations outlined in this Policy apply to all companies within EPMB Group, includes all individual working at all levels and grades, including directors, senior managers, managers, officers, employees (whether full-time, part-time, contract, interns or temporary), technical, consultants, agents, customers, suppliers, any other person associated with or acting on behalf of the Company and Board of Directors.

As such, each of individual is responsible for adhering to these standards in the business interactions, and to ensure that person acting on behalf of the Company understand that they are responsible for complying with this Policy when acting on behalf of the Company.

This Policy sets forth EPMB minimum compliance standards with respect to interactions with third parties. However, where local law, regulations require more stringent controls, then such more stringent controls must be followed.

 

 

 

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

 
  1. All forms of bribery and corruption are prohibited. In addition to bribery, employees, Directors and person acting on behalf of the Company/Group must not participate in any corrupt activity, such as extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering.
  2. Bribery may take the form exchange of money, goods, services, property, privilege, employment position or preferential treatment. Employees shall not therefore, whether directly or indirectly, offer, give, receive or solicit any item of value, in the attempt to illicitly influence the decisions or actions of a person in a position of trust within an organisation, either for the intended benefit the Group or the persons involved in the transaction.
  3. This Policy applies equally to its business dealings with commercial ('private sector') and government ('public sector') entities, and includes interactions with their directors, employees, technical, consultants, customers, suppliers, contractors, agents and other appointed representatives at all levels. Even the perception of bribery is to be avoided.
  4. This Policy applies to all countries worldwide, without exception and without regard to regional customs, local practices or competitive conditions.
  5. No Director, employee and person acting on behalf of the Company/Group will suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes or other illicit behaviour, even if such refusal may result in the company losing business or experiencing a delay in business operations.
  6. The Group recognises the value of integrity in its Directors, employees and person acting on behalf of the Company/Group. The Group's recruitment, training, performance evaluation, remuneration, recognition and promotion for all employees, shall be designed to recognise integrity.
  7. The Group does not offer employment to prospective employees in return for previous favour/in exchange of improper favour.
 
 
RECOGNITION OF LOCAL AND INTERNATIONAL LEGISLATION  
  1. The Group is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including but not limited to MACCA, Malaysian Penal Code (revised 1977) (and its amendments), the Companies Act 2016 (Malaysia). These laws prohibit bribery and corruption. Organisations are mandated to establish and maintain accurate books and records as well as adequate measures to prevent corrupt practices.
  2. In cases of conflict between mandatory law and the principles contained in this Policy the law shall prevail.
 
   
GIFTS, DONATION AND SPONSORSHIP  

The act of exchanging business gifts and receiving corporate hospitality can play an appropriate role in building or maintaining business relationships. However, gifts and hospitality are problematic if they create actual or perceived conflicts of interest, or otherwise appear to influence a business decision.

  1. The Group prohibits both giving and receiving gifts, discounts, favours or services (GIFTs), Donation and Sponsorship (D&S) from a current or potential customer, competitor, supplier, or service provider is prohibited if that benefit is a type or amount which has the potential to influence a person's business decision.
  2. Directors, employees and person acting on behalf of the Company/Group must comply with all applicable policies, procedures, laws and regulations related to the use of GIFTs in all countries in which the Group operates.
  3. The Group allows appropriate business-related GIFTs. Reasonable GIFTs are acceptable provided that the following guiding Principles are observed:
    • Principle 1: Transparency
      You should be comfortable to disclose to your colleagues the GIFTs and D&S that you offered/received.
    • Principle 2: Recipients
      You should only offer/accept GIFTs and D&S to/from those who will not put you in a position of conflict.
    • Principle 3: Ability to Influence
      The GIFTs and D&S must not be offered/accepted when there is a pending business decision.
    • Principle 4: Value
      The GIFTs and D&S must be modest and must not be so frequent as to place the recipient under an obligation.
    • Principle 5: Purpose
      The intention behind the GIFTs and D&S must not be interpreted as to gain unmerited advantage.
  4. Where possible, Directors, employees and person acting on behalf of the Company/Group should avoid from offering and/or accepting GIFTs and D&S to/from government officials. If a gift is deemed appropriate, a Corporate Gift for a specific purpose is encouraged as opposed to a Personal Gift. GIFTs must be reasonable and proportionate to the income of the Government official such that the no obligation is created by the provision of the hospitality resulting in a decision to the advantage of the business. All offers and acceptance of GIFT and D&S involving government officials must be approved by the Company. The GIFTs and D&S must also be declared.
  5. In respect of political contributions, funds or resources of the Group must not be used to make any direct or indirect political contributions on behalf of the Group without approval from the Board. Any appearance of making such contributions or expenditure to any political party, candidate or campaign, must also be avoided.
  6. Donations in the form of charity may be permissible depending on the circumstance but should be made directly to an official entity and be able to be disclosed publicly when required to.
 
   
BUSINESS ASSOCIATES
  1. As part of the Group's commitment to combat bribery, the Group expects all Business Associates to refrain from bribery.
  2. If suspicion of bribery and corruption arises in the dealings with any Business Associate, the Group shall seek an alternative provider of the services / goods.
  3. The Group expects all Business Associates acting on behalf the Group to contractually agree to refrain from bribery and corruption, and to adhere to the Vendor Code of Business Conduct.
  4. If the Group is not satisfied that bribery and corruption prevention has been upheld, due diligence shall be undertaken with regards to any Business Associate intending to act on the Group's behalf.
  5. The extent of the due diligence should be risk-based and shall include a bribery risk assessment. Due diligence may include a search through relevant databases, checking for relationships with public officials, and documenting the reasons for choosing one particular Business Associate over another.
  6. The Group shall endeavour to include clauses in all contracts enabling the Group to terminate any contract in which bribery or corruption has been observed.
 
   
FACILITATION PAYMENTS  
  1. The Group adopts a strict stance that disallows facilitation payments.
  2. Employees are expected to notify their immediate superior when encountered with any requests for a facilitation payment. In addition, if a payment has been made and employees are unsure of the nature, their immediate superior must be immediately notified and consulted. They must also ensure that the payment has been recorded transparently. The Group equally uphold the safety of all employees as priority.
 
   
RECORD-KEEPING  
  1. The Group must keep financial records and have appropriate internal controls in place which will evidence that business reason for making payments to third parties.
  2. To ensure all expenses claims relating to hospitality, gifts or entertainment incurred to third parties are submitted and approval has been obtained.
  3. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as customers, supplies and business contracts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.
 
   

RESPONSIBILITIES OF EMPLOYEES

 

Employees are responsible for understanding and complying with this Policy. In particular, the role of all Directors, employees and person acting on behalf of the Company/Group includes the following:

  1. Be familiar with applicable requirements and directives of the policy and communicate them to subordinates;
  2. Promptly record all transactions and payments accurately and in reasonable detail;
  3. Always raise suspicious transactions to immediate superiors for guidance on next course of action; and
  4. Promptly report violations or suspected violations through appropriate channels.

EPMB takes corruption and bribery very seriously. Any violation of this Policy will be regarded as serious matter by the Company and is likely to result in disciplinary action including termination, consistent with local law.

An employee will be accountable whether he/she pays a bribe himself/herself or whether he/she authorizes, assists, or conspires with someone else to violate an anti-corruption or anti-bribery law. Punishment for violating the law are against him/her as an individual and may include imprisonment, probation, mandated community service and significant monetary fines which will not be paid by EPMB.

 
   

CONFLICT OF INTEREST

 
  1. Conflicts of interest arise in situations where there is a personal interest that might be considered to interfere with that person's objectivity when performing duties or exercising judgement on behalf of the Group. Employees should avoid or deal appropriately with situations in which personal interest could conflict obligations or duties. Employees must not use their position, official working hours, Group resources and assets for personal gain or to the Group's disadvantage.
  2. Conflicts of interests including:
    • Dealing with suppliers, customers, agents and competitors;
    • Personal dealings with suppliers and customers;
    • Outside employment and activities outside the Group;
    • Board membership;
    • Family members and close personal relationships; and
    • Investment activities.
 
   
STAFF DECLARATIONS  
  1. All employees including new recruits shall complete trainings on the Code of Conduct and this Policy. Employees as well as new recruits are expected to pass the assessment at the end of the training and shall be complied with in the course of his/her employment.
  2. In addition, under circumstances of suspicious behaviour, allegations and/or investigations relating to bribery or corruption, Group Human Resources reserves all rights to request the relevant employee to declare information regarding assets owned as deemed necessary.
 
   
AWARENESS AND TRAINING  
  1. All existing employees operating in areas that are perceived as high risk will receive regular, relevant training on how to implement and adhere to this Policy.
  2. The zero-tolerance approach to corruption and bribery must be communicated to all supplies, contractors, agents, business and other partners at the outset of our relationship with them and as appropriate thereafter.
  3. Group Human Resources shall provide anti-bribery and anti-corruption training to New recruits/conducts awareness programmes for all Employees to refresh awareness of anti-bribery and anti-corruption measures, and to continuously promulgate integrity and ethics.
 
   
REPORTING OF POLICY VIOLATIONS  

Employees who encounter actual or suspected violations of this Policy are required to report their concerns. Each Employee has a responsibility to ensure that suspected - bribery and corruption incidents are reported promptly. The Group practices an open door policy and encourages all employees to share concerns and suggestions with superiors and colleagues who are able to address them in an appropriate manner. The secured whistleblowing channels as below :-

  1. Email:
    Senior Independent Director:
    shaariharon@yahoo.com
  2. Calls to EPMB Office: 03-7803 6663
  3. Letters to EPMB at:
    No. 8 & 10, Jalan Jurutera U1/23, Seksyen U1, Kawasan Perindustrian Hicom Glenmarie, 40150 Shah Alam, Selangor.

Reports made in good faith, either anonymously or otherwise, shall be addressed in a timely manner and without incurring fear of reprisal regardless of the outcome of any investigation.

 
   
SANCTIONS FOR NON-COMPLIANCE  
  1. The Group regards bribery and corruption as a serious matter. Non-compliance may lead to disciplinary action, up to and including termination of employment. Further legal action may also be taken in the event that the Group¡¯s interests have been harmed as a result of non-compliance.
  2. The Group shall notify the relevant regulatory authority if any identified bribery or corruption incidents have been proven beyond reasonable doubt.
  3. Where notification to the relevant regulatory authorities have been done, the Group shall provide full co-operation to the said regulatory authorities, including further action that such regulatory authority may decide to take against convicted employees.
 
   

MONITORING AND REVIEW

 

All Directors, employees and person acting on behalf of the Company/Group are responsible for the success of this Policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering corruption and bribery.

 
   
 
     
 
   
 
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