Anti-Bribery and Corruption Policy

What does the Policy cover?

• This Policy sets out the responsibilities of the Company and those who work for the Company on the requirement to observe and uphold the Company’s zero-tolerance position and stance on bribery and corruption.
• This Policy provides a source of information and guidance for those working for the Company, including related parties. It helps them recognise and deal with bribery and corruption, as well as understand their responsibilities.

Definitions

ABC Policy Statement

• Ambico Offshore Sdn. Bhd. is committed to complying with the relevant anti-bribery and corruption laws and regulations, breaches or violation of which may cause great damages to the Company. The consequences may include reputational damages, legal fines, imprisonment for persons responsible, eventual loss of business or key talents in the Company, etc.
• The Company / Board of Directors adopts a zero-tolerance approach towards bribery and corruption and the Company shall not pay nor receive any corruption gratification to or from anyone for any purpose;
• The Company shall uphold this position and stance across its business seriously and expects the same from stakeholders, both internal and external to the Company’s business, extending to all the Company’s business dealings and transactions in the countries we operate;
• Directors, Employees, Suppliers, Service Providers, Business Associates, Consultants and any third parties working with or for the Company (collectively called “Associated Persons”) shall adhere to and observe the Company’s anti-bribery and corruption position and stance and relevant provisions set out in the Company’s Policy; and
• The Company treats any violation of the Policy seriously and shall undertake necessary actions, including, but not limited to, review of employment or appointment, contracts (including termination of contracts), disciplinary actions, dismissal, and reporting to the authorities, consistent with the relevant laws and regulations.

Coverage of ABC Policy

• This Policy applies to all Associated Persons, comprising Employees (including Directors, trainees, casual workers, volunteers, interns, whether temporary, contract-basis or permanent), Suppliers, Service Providers, Business Associates, Consultants, Contractors, Agents, Sponsors, Intermediaries, or any other person or persons working with or for the Company or any of our subsidiaries, associates and related companies, no matter where they are located (within or outside of Malaysia). The definition of such Associated Persons accords with S17A (2) of the MACC Act 2009.
• In the context of this Policy, third party refers to any individual or organisation our Company meets and works with. It refers to actual and potential clients, customers, suppliers, consultants, service providers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, consultants, representatives and officials, politicians and public parties.
• Any arrangements our Company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with at least the minimum standards and procedures relating to anti-bribery and corruption.

Conflicts of Interest

• Conflicts of interest occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another. A conflict of interest may be actual, potential or perceived and may be financial or non-financial.
• Associated Persons should exercise caution in their personal relationships with customers, suppliers, competitors or businesses introduced or affiliated with a customer or supplier. This is to ensure there is no involvement of obligations that may prejudice or influence the business relationship or result in any conflict with their duties. If a conflict of interest arises between employees and a third party, the employees or the relevant department head should be made aware of the conflict and it be reported to director
• Associated Persons are required to avoid any situation or activity that compromises, or may compromise, their judgement or ability to act in the best interest of the Company and to avoid being in a position where their personal interests are in conflict (or could be in conflict) with the interests or business of the Company

Gifts, Entertainment, Hospitality and Travel

• List content text: This Policy does not prohibit normal business hospitality, so long as it is reasonable, appropriate, modest and bona fide corporate hospitality. Some examples of acceptable gifts and / or benefits are as follows : –
  
  

  a) token gifts offered in business situations or to all participants and attendees for example, work related seminars, conferences, trade and business events;

  b) gifts presented at work-related conferences, seminars and/or business events;

  c) gifts given in gratitude for hosting business events, conferences and/or seminars;

  d) refreshments or meals during meetings or as participants of work-related conferences and/or seminars; and meals for business purposes

• • As a general principle, the Associated Persons should not accept or give a gift to a third party if it is made with the intention of influencing the third party to obtain or retain business, or in exchange for favours or benefits. In addition, lavish or unreasonable gifts or hospitality should not be accepted nor given as such gifts or hospitality may be perceived or interpreted as attempts by the Associated Persons to obtain or receive favourable business treatment for personal benefits and to avoid the perception of improper influence on the decision making of the recipient. Hence, the intention behind the gifts or hospitality should always be considered.
• Associated Persons shall ensure that all gifts, entertainment, hospitality and travel made are legal and ethical under local laws and practices, and that such expenses incurred are made in accordance with the Company’s approval mandate.
• To avoid the reality, the appearance that business judgement may be improperly influenced or compromised and to protect the staff from any perception of improper conduct or conflicts of interest, employees should observe the following guidelines when deciding whether or not to accept gifts :-
• Gifts valued at Ringgit Malaysia RM.1,000.00 and above, regardless an individual item or accumulated in value, are expected to be declared.
• Where circumstances make it impossible, difficult or impractical to reject gift or where the rejection of the gift may affect the relationship with the customers or business associates (other than cash or cash equivalent) or rejecting them is deemed as offensive given the local custom, you may accept the gift(s). If accepted, it is deemed to have been accepted on behalf of the Company and become the property of the Company. The use of the gift is to be determined by the Director.
• Consumables like food gifts and hampers at nominal value will not need to be declared but instead be shared within the company staff.
• Associated Persons should obtain approval from his or her supervisor for business entertainment extended. As a guide, business meals are acceptable.
• Business entertainment that might compromise the Associated Persons ability to or appear to hinder his or her duties in a professional manner should not be accepted. The following deemed inappropriate :-
  
  

  1. Overseas trips in the form of paid holidays or holiday incentives;

  2. Accepting invites or tickets by the employee when the prospective host will not be present at the event with the employee.

• If there are doubts as to whether business entertainment might create the appearance of any conflict or impropriety, these situations can be referred to department head and Director.

Facilitation Payments and Kickbacks

• The Company does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
• The Company does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.