Anti-Corruption Policy and Procedures

POLICY

  1. The Board is committed to abide by the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act”) and laws countering bribery and corruption in all of the jurisdictions in which K-One operates or conducts its business.
  2. It is noted that even if the country in which an act of bribery takes place does not have anti-bribery laws which capture the relevant action, the MACC Act and the laws of another country in which K-One conducts its business may still apply. Although penalties may differ across the different jurisdictions in which K-One operates, bribery (or even the perception or an allegation of it):
    1. Will smear K-One’s reputation; and/or
    2. Could cost K-One significant amounts of money both in respect of potential fines and the time spent in dealing with such issues and may lead to serious penalties on individual members of K-One including imprisonment and fines, or even the forfeiture of critical operating licenses and permits.
  3. Therefore, the Board and all employees of K-One are committed to:
    1. Upholding anti-bribery and anti-corruption laws (“ABC” Laws”) that apply to K-One, including without limitation, the MACC Act;
    2. Not offering bribes or condoning the offering of bribes on K-One’s behalf;
    3. Not accepting bribes, or agreeing to them being accepted on K-One’s behalf;
    4. Maintaining accurate books and records;
    5. Making sure that K-One’s Representatives are aware of and abide by K-One’s values and policies;
    6. Avoiding doing business with or affiliating K-One with others who do not accept K-One’s values and policies and who may harm K-One’s reputation; and
    7. Ongoing monitoring of and auditing compliance with these principles.

GIFTS, HOSPITALITY, ENTERTAINMENT AND PROMOTIONAL OR OTHER ITEMS OF BUSINESS EXPENDITURE

  1. The general rule of K-One in receipt of gifts is to refuse or return the gifts and explanations are provided to the giver on the non-acceptance of the gifts.
  2. However, employees are allowed to accept and retain gift(s) of nominal value of promotional items or otherwise be approved by the Chief Executive Officer (CEO) or Chief Operations Officer (COO) of K-One.
  3. The value of gift(s) must not exceed RM150 and in any event, must not occur more than 3 times a year with the same entity.
  4. Hospitality must be unsolicited and not affect, or be perceived as affecting business judgment. Meals and entertainment should only be offered to and received from the K-One’s representative dealing with the customer or service provider in their role in K-One, is for purposes supported by K-One and may only be offered in conjunction with legitimate business meetings, conferences or events hosted, supported or sponsored by K-One. They may never be provided on a stand-alone basis.

FACILITATION PAYMENTS AND KICKBACKS

  1. K-One does not make and will not accept, facilitation payments, bribes or kickbacks of any kind.

CHARITABLE DONATIONS AND SPONSORSHIPS

  1. Any charitable donation or sponsorship made or offered on behalf of K-One must:
    1. not be related to, dependent on, or made in order to win or influence a business deal or decision;
    2. be given directly to the relevant charity or organization and not to an individual; and
    3. only be given with the prior consent of the CEO or COO of K-One.

The recipient will be required to provide a receipt for the contribution and confirmation of what the funds will be used for.

AGENTS, DISTRIBUTORS, SUPPLIERS AND JOINT VENTURE PARTNERS

  1. All arrangements with third parties should be subject to clear contractual terms including specific provisions requiring them to comply with standards and procedures in relation to bribery and corruption.
  2. Any third party suspected of engaging in bribery will be terminated. Appropriate due diligence will be undertaken before any third party is engaged. The appropriate level of due diligence will vary depending on the circumstances.
  3. Entering into any joint venture arrangement without prior approval from of the CEO/COO and the Board is prohibited.

DEALING WITH PUBLIC OFFICIALS

  1. The provision of money or anything else of value, no matter how small, to any public official for the purpose of influencing them in their official capacity is prohibited.
  2. Under special circumstances, where gifts of nominal value are to be given to public officials, approval of the CEO or COO is required.
  3. In addition, many public officials have their own rules regarding the acceptance of gifts and hospitality, etc., and these rules where applicable must be respected.
  4. In accordance with the K-One Code of Ethics, political donations by or on behalf of K-One are prohibited.

PROTECTION & REPORTING VIOLATIONS

  1. K-One is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the COO or CEO immediately. If the matter is not remedied, you should raise it formally with the Chairman of K-One. Concerns may also be raised by Representatives via alternate channels including through K-One’s whistle blowing channel. Refer to the Whistle Blowing Policy for further details..

COMMUNICATION

  1. K-One’s zero-tolerance approach to bribery and corruption is communicated to all K-One’s associated persons at the outset of K-One’s business relationship with them and as appropriate thereafter.
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