Anti-Bribery and Corruption Policy

Purpose and applicability

We have to practice what we preach. Adequate Procedures Sdn Bhd ("our firm") is committed to conducting our business ethically and with integrity. We take reasonable and appropriate measures to ensure that our firm does not participate in any corrupt activities.

This policy is meant to communicate  our firm's commitment in preventing and curbing bribery and corruption. This policy sets out the responsibility of those that work with us or for us or on behalf of us, whether under contractual arrangement or not (collectively referred to "associated person"), with regards to observing our firm's commitment.

All associated persons are expected to read and understand this policy. Violation of any provision stated in this policy may result in disciplinary action, including termination of any contractual arrangement.  

This policy is not meant to be exhaustive and there may be additional obligations that are required to be met in working for, with or on our firm's behalf. For all intent and purposes, all associated persons shall always observe and ensure compliance with all applicable laws in the performance of their duties. 

Compliance with laws in Malaysia

Our firm are bound by and will comply with all laws in Malaysia. Our firm shall constantly uphold all such laws. 

In complying with the local laws, our firm adopts the definition of bribery as provided in the Malaysian Anti-Bribery Commission Act 2009 through the concept of "gratification".

Basic principle and rules

All associated persons shall not bribe or must not use any intermediary to commit acts of bribery.  Associated persons must refrain from offering, promising, giving, receiving or soliciting anything of value that may be perceived as "gratification" and be viewed as an attempt to illicitly influence the decision or action of a person in a position of trust for the intended benefit of our firm. 

This policy does not prohibit normal gestures o business hospitality and goodwill, so long the giving or receiving of gifts, hospitality and entertainment meets the following conditions: 

• Not made with the intention to influence the recipient to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange of favour or benefit;
• Not made with the suggestion that a return of favour is expected;
• Complies with the local law;
• Given in the name of the company, not in an individual's name;
• Is reasonable, modest, infrequent and appropriate to the circumstances; and
• Given or received openly, not secretly. 

Our firm does not condone any form of unofficial facilitation payment, unless there is no other alternative but to make the payment in order to protect themselves from injury, harm, loss of life or liberty. 

Our firm, by itself, shall not make any contributions, whether in-kind or by any other means, to support any political party, politician, candidate or any other agencies or bodies that may be aligned to a political cause.

Our firm accepts and encourages the act of donating to charities that could come in form of services, goods, time or direct financial contributions. Associated persons are advised that proper due diligence needs to be exercised to ensure that such donations are not used as a scheme to conceal bribery, legally or ethically. 

Responsibilities 

The Board of Directors of our firm shall be ultimately responsible to ensure that this policy complies with our firm's legal and ethical obligations and that all associated persons that are under our control complies with it. 

Our firm recognises the importance of raising concerns on any suspected or actual bribery offences and encourages associated persons to come forth to raise such a report through our firm's whistleblowing platform. 

For ease of reference, concerns can be raised through this link (https://suara.live/concern/index/24)

No employees of our firm shall suffer any detrimental treatment for refusing to take part in bribery or corruption, or for reporting any concerns in good faith on actual or suspected bribery offence that has taken place or will take place, even if such action may be disadvantageous to our firm (e.g. loss of business). Any person that retaliates against a person that raised a concern in good faith shall be subject to disciplinary actions, including dismissal and termination. 

Record keeping

Our firm shall prepare and maintain our books and records accurately and will have appropriate internal controls in place to evidence all payments made, whether in-kind or not.