ANTI-BRIBERY & ANTI-CORRUPTION (“ABC”) POLICY

1.0 OVERVIEW

  1. Elegant World (M) Sdn. Bhd. and its Group of Companies (“the Group”) practices a strict zero-tolerance approach against bribery and corruption. The Group upholds a culture of integrity and all applicable laws in relation to anti-bribery and anti-corruption. The Group of Companies are as follows:-
    1. Elegant World (M) Sdn. Bhd.
    2. Elken Sdn. Bhd.
    3. Elken Global Sdn. Bhd.
    4. Elken Service Sdn. Bhd.
    5. Butbo Sdn. Bhd. and
    6. Gene Express Sdn. Bhd.
  2. This ABC Policy aims to set out the framework and parameters of reference and guidance to all Stakeholders (including but not limited to directors, distributors/members, suppliers, service providers, employees), whether they are working for or with the Group in complying with the applicable anti-bribery and anti-corruption laws.
  3. “Bribery” and “Corruption” are the offering, promising, giving, accepting or soliciting of an undue advantage or gratification of any value, (which can be financial or non-financial, directly or indirectly and in violation of applicable laws), as an inducement or reward for a person acting or refrain from acting in relation to the performance of his/her duties. (M)

2.0 GUIDANCE ON COMMON FORMS OF BRIBERY AND CORRUPTION

  1. No-Gift Policy
    The Group has a “no gift policy” where all Stakeholders shall not provide, solicit and employees shall not accept gifts from any third party that may have direct/indirect business interest with the Group. The word “gift” means any item (pens, calendars, hats, bags, angpau, etc) having any cost or financial value, including food or beverages, and including vendor-sponsored meals, parties or tickets to sporting and/or entertainment events. Thank you notes, certificates, or other written forms of recognition of our employees are allowed.
  2. Entertainment & Hospitality
    The Group is 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. However, the Group prohibits the giving and receiving of hospitality and/or entertain where it would be illegal or in breach of any applicable laws.
  3. Donations and Sponsorships
    As part of the Group’s commitment to provide financial/non-financial assistance for its corporate social responsibility initiatives, proper due diligence must be carried out to ensure that the contribution for the intended for association/organisation is legitimate and in accordance to Finance Policies and Procedures.
  4. Facilitation Payments
    The Group strictly prohibits giving (whether directly or indirectly) any facilitation and/or extortion payments in return for any business advantage for the Group.
  5. Conflict of Interest
    Conflict of interest may arise where a person’s objectivity could be interfered with when he/she is performing duties or exercising judgment on behalf of the Group, whether it is in relation to receiving or giving any benefit (in cash or in-kind) that could result in conflicting with their obligations or duties for any personal gain that could result in the Group’s benefit.
  6. Procurement
    Procurement must be conducted in accordance with the Group’s policies, internal processes and procedures relating to procurement. Stakeholders are prohibited from offering, promising, requesting, paying or receiving any form of bribe or facilitation of payment as part of the procurement process.
  7. Tender
    Any tender processes participated by any company shall be fair, transparent and in accordance with the Group’s tendering procedures.

3.0 WHISTLEBLOWING

  1. The Group encourages Stakeholders to report any actual, suspected bribery/corruption occurring in the course of business/work, with supporting evidence/detailed information via email to abc.compliance@elken.com. Whistleblowing made in good faith will be given the protection of confidentiality and against retaliation. Anonymous complaints will not be entertained.

4.0 MONITORING AND REVIEWING

  1. The Group will conduct a periodical risk assessment and review of its subsidiaries’ ABC standard operating procedures (“SOP”) at least once every three years to ensure that the Group of Companies continue to have relevant, appropriate and effective monitoring system to uphold the Group’s ABC policy.
  2. An internal audit of the Group’s ABC compliances will be conducted from time-to-time. Any findings will be reported to and acted upon by the ABC Committee.

5.0 TRAINING AND COMMUNICATION

  1. The Group communicates this ABC Policy to its Stakeholders (where appropriate and applicable) and trains its employees through various communication channels to ensure its ABC compliance are in accordance with the laws. A copy of the ABC Policy is made available at the Group’s corporate websites.

6.0 VIOLATION AND INVESTIGATION

  1. The Group views any violation of the ABC Policy and/or its corresponding SOPs seriously and upon investigation of any conduct found non-compliant or violates any applicable laws shall be reported to the ABC Committee and if proven may result in termination of contract, suspension/termination of employment or reporting of the criminal offence to MACC.
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