Anti-Bribery Policy

We, the management and staff of

GRAND SAGA SDN BHD

are committed to:

1. Anti-Bribery and Corruption Policy (‘ABAC Policy’)

  1. The Organisation’s policy is that bribery and corruption in all its forms as it relates to the Organisation’s activities are prohibited.
  2. Bribery may take the form of anything of value, such as money, goods, services, property, privilege, employment position or preferential treatment. Employees and business associates 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 of the Organisation or the persons involved in the transaction.
  3. The Organisation is committed to conducting its business ethically and in compliance with all applicable anti-bribery and anti-corruption laws and regulations in every country where we do business, without exception and without regard to regional customs, local practices, or competitive conditions.
  4. The Organisation empowers the ABMS Committee to independently oversee the implementation, compliance and reporting on the performance of the ABMS.
  5. The Organisation shall conduct regular risk assessments to identify the bribery risks affecting the business, set anti-bribery objectives, and assess the effectiveness of the controls in achieving those objectives.
  6. The Organisation shall promote awareness of anti-bribery to all employees at all levels and functions and to our business associates;
  7. No employees will suffer demotion, penalty, or other adverse consequences in retaliation for refusing to pay or receive bribes, or participate in other illicit behaviour, even if such refusal may result in the Organisation losing business or experiencing a delay in operations.
  8. Employees who, in the course of their activities relating to their employment at the Organisation, encounter actual or suspected violations of this policy, are required to report their concerns using the available reporting channels. Reports made in good faith, either anonymously or otherwise, shall be investigated in a timely manner and without incurring fear of reprisal, regardless of the outcome.
  9. Retaliation in any form against employees where the person has, in good faith, reported a violation or possible violation of this policy is strictly prohibited. Any employees found to have deliberately acted against the interests of any person who has in good faith reported a violation or possible violation of this policy shall be subjected to disciplinary proceedings including demotion, suspension, dismissal, or other actions (including legal action) which the Organisation may pursue. The same policy applies to external parties who have reported a violation or possible violation of this policy.
  10. The Organisation shall ensure compliance with the ABMS requirements by all available means, including undertaking continual improvement action whenever appropriate.
  11. The anti-bribery and corruption policy applies equally to its business dealings with commercial (‘private sector’) and Government (‘public sector’) entities. Even the possible appearance of bribery is to be avoided, in particular when dealing with government officials.

2. Responsibilities of the Organisation’s Directors and Employees

a. All directors and employees are required to carry out their responsibilities and obligations relating to the Organisation’s ABAC Policy, which includes the following:

  • Be familiar with applicable requirements and directives of this policy, understand and communicate them to subordinates;
  • Promptly record all transactions and payments in the Organisation’s books and records accurately and with reasonable detail;
  • Ask the ABMS Compliance Officer if any questions about this policy arise or if there is a lack of clarity about the required action in a particular situation;
  • Always raise suspicious transactions and other “red flags” (indicators of bribery) to immediate superiors or the ABMS Compliance Officer directly for guidance on the next course of action;
  • Be alert to indications or evidence of possible violations of this policy;
  • Sign the Integrity Pledge;
  • Declare any actual, potential, or perceived conflicts of interest to immediate superior and top-level management as soon as they become aware of them;
  • Promptly report violations or suspected violations through appropriate channels;
  • Attend mandatory anti-bribery training as required by the Organisation; and
  • Not misusing the directors’ and employees’ position or the Organisation’s name for personal advantage.

b. When dealing with business associates, the directors and employees shall not:

  • Express unexplained or unjustifiable preference for certain parties;
  • Exert improper influence to obtain benefits from them; and
  • Directly or indirectly demand or accept any form of bribe payments, in cash or in kind for a specific favour or improper advantage from them.

c. When dealing with external parties in a position to make a decision to the Organisation’s benefit (such as a government official or business associate), directors and employees shall not:

  • Offer, promise or make any attempt at dishonestly influencing the person’s decision by directly or indirectly offering or making a promise of bribe payments, in cash or in kind;
  • Be involved in any discussions regarding business or employment opportunities, for the benefit of the external party;
  • Otherwise misuse the resources, decision-making authority and other delegated powers given by the Organisation, in order to illicitly secure an outcome which would be to the commercial advantage to themselves and/or the Organisation; and
  • Make any attempt at dishonestly influencing the external parties’ decisions by offering, promising, or conferring advantage.

d. Heads of Department/ Managers are responsible for ensuring that the Organisation’s anti-bribery and corruption policies are properly communicated and complied with within their department or function, and that subordinates in position which have been identified as exposed to bribery or high risk attend relevant training. Managers are also required to communicate the ABAC Policy as contained in this Manual to the business associates.

3. Human Resource

  1. The Organisation recognises the value of integrity in its directors, employees, and business associates. The Organisation’s recruitment, training, performance evaluation, remuneration, recognition, and promotion for all employees, including management, are designed to recognise integrity.
  2. Employees proved to have been involved in bribery and corruption will be subject to disciplinary action, up to and including termination of employment.
  3. Applicants who have improperly favoured the Organisation during their tenure in a previous employment will not be given any preference in employment opportunities at the Organisation.

4. Audit and Compliance

  1. Regular audits shall be conducted to ensure compliance to this ABMS programme. Such audits may be conducted internally by the Organisation or by an external party. Audit documentation should include performance improvement action plans.
  2. The results of audits shall be reported to the Board, top-level management and the ABMS Committee and acted upon.
  3. Serious matters of non-compliance as identified by the audit and other means shall be reported to the top-level management in a timely manner for suitable action to be taken.

5. Sanctions for Non-Compliance

  1. The Organisation regards bribery as a serious matter and will apply penalties in the event of non-compliance to this ABAC Policy. For employees, non-compliance may lead to disciplinary action, up to and including termination of employment.
  2. For external parties, non-compliance may lead to penalties including termination of contract. Further legal action may also be taken in the event that the Organisation’s interests have been harmed by the results on non-compliance by individuals and organisations.

6. Monitoring and Continual Improvement

  1. The Organisation is committed to continually improve the operations and effectiveness of the ABMS programme.
  2. The Organisation shall monitor its operating environment, identify changes in bribery risk, and seek opportunities for improving the ABMS programme.
  3. The top-level management shall ensure regular assessments of the ABMS programme are carried out, to ensure its scope, policies, procedures, and controls match the bribery related risks faced by the Organisation.
  4. The Organisation endeavours to impact the business environment where it operates. This includes supporting initiatives in the private and public sectors which are likely to improve the integrity of its operating environment.