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Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy

1. Introduction Awesome Technology Resources (“The Company”), located at Unit B2-2-3, Solaris Dutamas, 1, Jalan Dutamas 1, 50480 Kuala Lumpur, and incorporated in Malaysia, is committed to conducting business with the highest level of integrity and transparency. This Anti-Bribery and Corruption Policy (“Policy”) outlines the Company’s commitment to preventing bribery and corruption in all forms and ensuring compliance with the Malaysian Anti-Corruption Commission Act 2009 (MACC Act) and other applicable laws.

2. Purpose This Policy aims to:

  • Promote a culture of integrity and transparency within the Company.
  • Ensure compliance with all applicable anti-bribery and corruption laws.
  • Provide guidance on recognizing and preventing bribery and corruption.
  • Establish clear procedures for reporting violations.

3. Scope This Policy applies to all employees, directors, officers, consultants, agents, contractors, suppliers, and any third parties acting on behalf of the Company (“Associated Persons”).

4. Definition of Bribery and Corruption

  • Bribery: Offering, promising, giving, accepting, or soliciting something of value as an inducement or reward to improperly influence a decision or action.
  • Corruption: Abuse of entrusted power for private gain, which includes activities such as bribery, fraud, embezzlement, and extortion.

5. Policy Statement The Company strictly prohibits all forms of bribery and corruption. This includes:

  • Offering or accepting bribes in any form, whether directly or indirectly.
  • Facilitating payments to expedite routine governmental actions.
  • Making charitable contributions or sponsorships as a means to gain an improper business advantage.

6. Responsibilities

  • Employees: All employees must adhere to this Policy, complete mandatory training, and report any suspected violations.
  • Management: The management team is responsible for leading by example, ensuring compliance, and fostering a culture of integrity.
  • Third Parties: Third parties acting on behalf of the Company must comply with this Policy and are subject to appropriate due diligence procedures.

7. Gifts, Hospitality, and Entertainment

  • The Company recognizes that giving or receiving modest gifts and hospitality can be a legitimate business activity. However, such activities must not:
    • Influence or appear to influence business decisions.
    • Violate any applicable laws or regulations.
    • Exceed reasonable and customary business practices.

Employees must record all gifts, hospitality, and entertainment exceeding a defined threshold in the Company’s Gift and Hospitality Register.

8. Reporting and Whistleblowing The Company encourages all employees and third parties to report any concerns or suspicions of bribery and corruption. Reports can be made anonymously through the Company’s whistleblowing channel at [Insert Contact Information]. All reports will be treated confidentially and investigated promptly.

9. Training and Awareness The Company provides regular training to employees and Associated Persons to ensure they understand this Policy, recognize bribery and corruption, and act in compliance with the law.

10. Record-Keeping The Company maintains accurate and detailed records to demonstrate compliance with this Policy. This includes records of transactions, gifts, and due diligence conducted on third parties.

11. Consequences of Non-Compliance Non-compliance with this Policy may result in disciplinary action, including termination of employment or contracts. Violations of anti-bribery and corruption laws may lead to severe legal penalties, including fines and imprisonment.

12. Monitoring and Review This Policy will be reviewed annually or as necessary to ensure it remains relevant and effective. Updates will be communicated to all employees and Associated Persons.

13. Contact Information For questions or concerns regarding this Policy, please contact:

  • Compliance Officer: Eddie Lee
  • Whistleblowing Hotline: +60 3 6262 3777

By adopting this Policy, Awesome Technology Resources reaffirms its commitment to ethical business practices and compliance with anti-bribery and corruption laws.