ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

PURPOSE

      • To set out the responsibilities of IDEALUBIB, and of those working for IDEALUBIB in observing the IDEALUBIB’s strong position on bribery and corruption,
      • To establish controls to ensure compliance with all applicable anti-bribery and anti-corruption regulations, and
      • To provide information and guidance to those working for IDEALUBIB on ways to recognize and deal with bribery and corruption issues

OUR POLICY AND PRINCIPLE

IDEALUBIB is committed to conducting its business with integrity and in an ethical manner. IDEALUBIB has a zero-tolerance approach against all forms of bribery and corruption and are committed to act professionally and fairly in all our relationships and business dealings. This means avoiding practices of bribery and corruption of all forms in the Company’s daily operations.

We will uphold all laws relevant to countering bribery and corruption and remain bound by the laws in Malaysia. Bribery and corruption are criminal offences and are punishable for both individuals and companies.

SCOPE

This Policy applies to all companies within IDEALUBIB group. This includes all individuals working at all levels and grades, including directors, senior managers, managers, officers, employees (whether full-time, part-time, contract or temporary), consultants, contractors, agents, sponsors, suppliers, customers, any third parties and any other person associated with us.

ANTI-BRIBERY AND ANTI CORRUPTION POLICY

The Malaysian Anti-Corruption Commission in its official portal describes “corruption” as an act of giving or receiving any gratification or reward in the form of cash or in-kind of high value for performing a task in relation to his/her job function or activity.

The MACC Act stipulates four main offences:

      • Soliciting/Receiving Gratification (Bribe)
      • Offering/Giving Gratification (Bribe)
      • Intending to Deceive (False Claim)
      • Using Office or Position for Gratification (Bribe) (Abuse of Power/Position)

The MACC (Amendment) Act 2018, which will be in force on 1 June 2020, introduces two more offences:

      • Offering/Giving Gratification by commercial organization (Corporate Liability)
      • Deemed Parallel Personal Liability for Senior Personnel (Personal Liability)

Bribery and corruption in all its forms as it relates to IDEALUBIB’s activities are prohibited. Bribery and corruption may take the form of anything of value, such as money, goods, services, property, privilege, employment position or preferential treatment.

IDEALUBIB’s personnel and its business associates shall not, 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 organization, either for the intended benefit of the Company or the persons involved in the transaction.

The anti-bribery and anti-corruption policies apply equally to its business dealings with both private and public sector entities, and include their directors, personnel, agents and other appointed representatives.

No employees or external parties will suffer demotion, penalty or other adverse consequences in retaliation for refusing to pay or receive bribes or participate in any illicit behaviour.

GIFTS, ENTERTAINMENT, DONATION AND HOSPITALITY

IDEALUBIB’s personnel are strictly prohibited from directly or indirectly receiving or soliciting for gifts from any party for themselves or for or on behalf of IDEALUBIB. IDEALUBIB’s personnel shall not accept any gift or hospitality whether it’s in cash or in kind, and/or when there is any suggestion that a return favour will be expected or implied.

Our personnel must not directly or indirectly provide or offer to provide entertainment with a view to cause undue influence or in exchange for favours. Any form of entertainment must not be accepted in exchange for an exercise or non-exercise of their job function or activity. Such acts are considered corruption.

Similarly, IDEALUBIB prohibits the giving and receiving of donations to influence business decisions.

IDEALUBIB’s personnel must not directly or indirectly solicit or accept corporate hospitality of any form that is excessive, inappropriate, illegal or given in response to, in anticipation of, or to influence a favourable business decision.

REGULAR MONITORING AND REVIEW

IDEALUBIB is committed to complying with the anti-bribery and anti-corruption requirements as a continuous effort to maintain the reputation and standards of IDEALUBIB.

IDEALUBIB shall monitor the legal and regulatory regimes where it operates and any changes to its business environment and risks and identify opportunities for IDEALUBIB improvement. Regular assessment shall be carried out to ensure its policies, scope, procedures and controls match the bribery and corruption related risks faced by the Company.

IDEALUBIB takes bribery and corruption very seriously. Any violation of the policies will be regarded as serious matter by the Company and is likely to result in disciplinary action, including termination, consistent with the law.

This Policy will be updated, amended or revised when necessary from time to time to ensure its adequacy and effectiveness in implementations and enforcements.