The Company realizes the importance of conducting its business in accordance with the principles of good corporate governance, of competing in an equitable and transparent manner, and of complying with all applicable laws; as well as is committed to being against corruption. As such, the Company has determined an Anti-Corruption Policy together with associated operating guidelines and procedures as the Code of Business Conducts and Ethics for use and adherence by the Company, its Subsidiary Companies and all persons within the organization and also by those external people who are involved in doing business with the Company, so that every party can comply to these guidelines. This is in order to jointly promote anti-corruption practices under the same Anti-Corruption Policy and support the building up a full understanding of the Company’s intent and position on being against corruption that will result in a positive corporate image for the Company, which will then lead to the ongoing development and sustainable growth of the Company.
The Company has arranged for the dissemination of information together with associated training on the subject of anti-corruption, in order to create awareness, knowledge and understanding on the part of all those involved – namely: Board Directors, the Management and all staff. This is so that everyone will not support or act in giving all types of bribery within the respective business units under their control; or will not ask for any monetary payments, goods, or any other type of benefits in an improper manner regardless of whether it is for the benefit of the Company, for themselves, for their family, or for their close friends. As such, in the event that it is found out that someone has not acted in compliance with this policy, that person will be subjected to disciplinary punishment or legal prosecution; whereby the type and degree of punishment will be based on the true facts and associated situation as applicable.
The Company has also undertaken an assessment of the risks relating to the possible occurrence of acts of corruption within the various established business operations procedures on a regular basis; as well as has determined various appropriate measures to rectify the problem if it occurs together with establishing channels of communications for submitting any relevant information or complaints to be received by the Management as applicable whenever anyone comes across any situation of alleged acts of corruption, or any wrongdoings and improper behavior.
The Company has signed up in being part of the “Private Sector Collective Action Against Corruption” and joined in stating its position on being against corruption, so as to underscore its genuine intent and commitment in being against corruption for the benefit of developing both the organization and the country as a whole in a sustainable manner.
Submitting Information or Complaints
The Company’s Board of Directors has established procedures together with setting up channels of communications to receive relevant information and to deal with complaints received from any Stakeholders; whereby various anti-corruption measures have been established to prevent any acts of corruption that are to be operating guidelines for adherence by Board Directors, the Management and staff, together with the ability to submit any complaints. In the event that any person comes across any suspected improper actions, they can inform the Internal Audit Unit or submit a formal written note to the Chief Executive Officer, whereby the Company has set up a box to receive any complaints or information with only the CEO possessing the key to open this complaints box. Alternatively, a message can be sent directly to the CEO immediately and at any time.
Upon receiving relevant information or complaints from any Stakeholder, who comes across or suspects any possible wrongdoing by a staff member or business unit that is an act of non-compliance with or violation of the law or policy and regulations relating to good corporate governance and the Code of Business Conduct and Ethics, which may cause damage to the Company, a committee will be set up to investigate the true facts; whereby working together with the involved business unit, this committee will proceed with the investigation in a careful, equitable and transparent manner, as well as will then report its findings to the Internal Audit Unit and the Senior Management together with recommendations on how to resolve the situation in an appropriate time and manner. Further, after the Internal Audit Unit has reviewed the report and concurs with the recommendations, the Committee will then give feedback of its findings to the informant or complainant.
Protection of the Rights of Informants
The Company has arranged various channels of communications for informants to use in submitting complaints on any alleged wrongdoings relating to a violation of any applicable laws and the Code of Business Conducts and Ethics, or on any acts of misconducts by people within the organization or by other Stakeholders involved with the Company; whereby the informant or complainant must provide details of the alleged wrongdoing together with his/her name, address and contact telephone number by sending the information in a letter by ordinary mail or by email to the Internal Audit Unit or directly to the CEO or via any other designated channel of communication specified by the Company. As such, the Company will keep confidential the name and contact details of the informant or complainant, who will then receive full protection until the investigation process is completed, during which period all details will not be revealed to any other parties who have no duties in being involved with the investigation except as required by the applicable laws; as well as will restrict the specific rights to reveal any details on the part of those persons involved and responsible for the investigation of the complainant.