Anti-Bribery &
Corruption Policy

Effective Date: 1 September 2023

1. Gift, Hospitality and Entertainment

(a) “No Gift” Policy

At MISHU Group (“Group”, “we”, “our”, “us”), we adhere to a “No Gift” Policy where our employees are prohibited from offering or receiving gifts, except under certain circumstances. If allowed, the value of such gift must not exceed RM500.00 per item and the frequency of gift exchanges with the same person must not exceed four (4) times per year. Additionally, gift exchanges should be avoided during specific periods like contract negotiations.

(b) Receiving Gifts in Limited Circumstances

Employees may accept gifts if certain pre-conditions laid down in the Group’s Anti-Bribery and Corruption Policy (“Policy”) are met, including obtaining prior written approval.
If a gift is accepted without approval, it must be declared and assessed.
Gifts that are in the form of cash or cash equivalents such as gift certificates, loans, kickbacks, commissions, coupons and discounts should not be accepted.

Gifts may only be given to third parties in situations that are consistent with customary business practices (e.g., cultural festivities) and are lawful. These gifts should be nominal in value and must not be interpreted as an act of bribery, including inducements for trade.

(d) Exceptions to “No Gift” Policy (double exceptions)

The exception to “No Gift” Policy will apply under the following circumstances, provided that it does not contravene any of the provisions under this Policy and the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act”):

Exchange of gifts between companies during official visits/ courtesy calls.
Gifts from any company within the Group (“Company”) to external companies or individuals in relation to their official functions, events and celebrations and vice versa.
Token gifts of nominal value bearing the Company’s logo.
Gifts exchanged with customers or business partners during festive occasions, in accordance with cultural traditions.
Gifts provided as part of the Company’s Corporate Social Responsibility (“CSR”) program.

(e) Hospitality and Entertainment

As a general rule, we prohibit offering or acceptance of hospitality and entertainment.
Exceptions to the general rule as stated above may be considered by the Company, provided that the conditions laid down in the Policy have been fulfilled.

2. Donations, Sponsorships and Charitable Contributions

(a) All donations, sponsorships and charitable contributions proposed or intended to be made in the Company’s name are subject to the pre-conditions laid down in the Policy.

3. Political Contributions

(a) The Company will not make or offer any form of political contributions to political parties, political party officials or candidates nominated for political office.

4. Facilitation Payments

(a) Facilitation payments (also known as ‘grease payments’ or ‘expediting payments’), refer to payments made to any individual, corporation, partnership, association, limited liability company, trust, governmental authority or other entity or organisation (whether or not having a separate legal personality), to expedite routine or administrative tasks.

(b) Our employees are not allowed to give, offer or promise facilitation payments in the course of performing their duties. Similarly, they are prohibited from accepting or soliciting such payments from you, whether in cash or in kind, unless such payments are explicitly permitted under our policy for expediting our internal processes.

5. Recruitment, Promotion and Support of Employees

(a) Our employee recruitment process follows approved criteria and procedures.

(b) Background checks will be conducted on candidates, to ensure that they have no history of bribery or corruption.

(c) Employment benefits and remuneration are determined solely based on qualifications, skills, experience and performance. We prioritise fairness and equity, ensuring the compensation aligns with individual contributions and achievements.

6. Dealing with Associated Persons

(a) We expect ethical conducts and shared values from our Associated Persons (i.e. any external party with whom the Group has, or intends to establish, a business relationship as well as any third parties engaged in performing works or providing services for or on behalf of the Group) in all their business interactions.

(b) We maintain a zero-tolerance approach towards Associated Persons who do not conduct themselves or their businesses in accordance with this Policy or engage in conduct that brings us into disrepute and/or causes any legal implications on us. Non-compliance by any Associated Person may lead to review and potential termination of agreements or relationships with us.

7. Dealing with Public Officials

(a) “Public Officials” means any persons who hold positions of authority, responsibility or influence within the government or public sector.

(b) Strict prohibition of illegal payments, such as bribes and kickbacks, to Public Officials.

(c) Any gift, hospitality and entertainment offered to Public Officials require prior approval, must be appropriate and compliant with laws.

8. Violation of this Policy

(a) We treat bribery and acts of corruption as serious offences. In the event that an employee or Associated Person engages in bribery or any act of corruption, we will impose appropriate penalties on the employee or Associated Person.

(b) We reserve the right to report violations to relevant authorities and regulatory bodies.

9. Reporting of Violations (Whistle-blowing Policy)

(a) We strongly encourage the reporting (whistleblowing) of any actual or suspected cases of bribery and corruption.

(b) A specific reporting channel has been established and is maintained to receive information regarding violations of this Policy and other instances of improper conduct by employees or Associated Persons. This channel is open to employees, Associated Persons and the general public.

(c) If an employee, Associated Person or member of the public has reasonable grounds to suspect, believe or becomes aware of any improper conduct, they are encouraged to report it in writing to the Group’s Human Resources Department at [email protected].

(d) We are committed to ensuring that no repercussions or retaliation will be taken against anyone who reports improper conduct in good faith, even if the allegations are unfounded. All reports will be treated with utmost confidentiality, and appropriate actions will be taken to address the reported concerns.