ANTI CORRUPTION AND BRIBERY POLICY

MESB BERHAD (Registration No. 199501008356 [337554-D])

ANTI CORRUPTION AND BRIBERY POLICY

1. Purpose

MESB Berhad (“the Company) and its subsidiary companies (“the Group”) are committed to conduct its business with integrity and promote better governance culture and ethical behaviour within the Group. The Group does not tolerate corruption or bribery in any form.

2. Policy

This Policy shall apply to all directors and employees of the Group. Furthermore, all persons acting as representatives of the Group shall comply with the provisions of this Policy and shall promote, to the extent possible, the enforcement of its principles at the companies and entities at which they represent the Group.

The Policy should be read in conjunction with the Code of Conduct and Whistle-Blowing Policy of the Company.

3. Compliance

All employees and the directors of the Group are required to comply with the Policy and all relevant anti-bribery and corruption laws including the Malaysia Anti-Corruption Act and other similar anti-bribery laws.

You shall:

  •  Not receive, offer, promise, authorise or give gifts in any form directly or through a third party (vendor, suppliers, business partner, or other intermediary) or for the benefit of the recipient or some other person, which the gifts reasonably expected to secure any improper advantage, or to influence a business decision.
  • Not receive, offer, promise, authorise or give anything which may consider as a bribe to a government official, agent or representative in order to speed up or facilitate actions or processes.
  • Ensure gifts, hospitality, donation, and/or entertainment incurred and received are reported in accordance with the relevant policies of the Group;
  • Not engage in any activity that might lead to a breach of this policy.
  • Exercise good judgement when giving or receiving gifts, in order to avoid conflict of interest or creating a negative perception of bribery and corruption.

Gifts exempted from this policy are as follow:-

  • reasonable and not excessive;
  • appropriate and consistent with reasonable business practice;
  • they must be provided with the intent only to build or maintain a business relationship or offer normal courtesy, rather than to influence the recipient’s objectivity in making a specific business decision;
  • permissible under all applicable laws, rules and regulations.

If there is any doubt about whether a gift or entertainment is permissible, talk to the manager, head of the operating unit or directors.

4.  Responsibilities

Every employee has a duty to speak out against suspected acts of bribery or corrupt practices. Everyone has a responsibility to help prevent, detect and report instances of suspected bribery and wrong doing under the Whistleblowing Policy.

It is the responsibility of the head of department to ensure those reporting to them are made aware of and understand this Policy. Ultimate responsibility for compliance with this policy throughout the group shall be taken by the Chief Executive Officer (“CEO”).

Implementation and updating of the Anti-Bribery and Anti-Corruption Policy are in the responsibility and duties of the Board of Directors.

5. Risk Management Assessment  

The risks associated with fraud, corruption and bribery shall consider in evaluating the effectiveness of risk management, and particularly in all processes that involving the relationships thereof with third parties.

6. Reporting

Any individual and employee with any suspicious, concerns or believes regarding a violation with this Policy has occurred or may occur in future, should raise up, notify the  Chairman  of  the  Audit Committee or CEO and shall make report to the Company via the channel outlined in the Group’s Whistleblowing Policy, which available at www.mesbbhd.com.

7. Consequences of violation

Any person who breaches this Policy will face disciplinary action, which could result in dismissal and/or reporting to the relevant regulatory authorities.  The Group reserves its right to terminate its contractual relationship with other persons if they breach this Policy.

8. Monitor and Review

This Policy will be reviewed and updated as needed to ensure it continues to be adequate and effective.