ANTI-BRIBERY AND PREVENTION OF CORRUPTION

Cogebi Asia Sdn Bhd (“CASB”) is committed to the high standards of code of conduct and code of ethics in our business activities.  We require professional and integrity commitment from all employees and directors of CASB in business dealings.          

The Anti-Bribery and Corruption (“ABC”) Policy has set a clear statement that CASB commitment to zero tolerance on any form of bribery and corruption which is in line with the laws in Malaysia.  This  Policy  is  applicable  to  anyone  who  is  employed  by  or  worked in CASB be it permanent, probationary, contract or temporary basis, directors, business partners and associates. 

CASB committed to implement and enforce strict prohibitions in any act of bribery and corruption regardless of its form.  All its employees are mandatory to observe and apply CASB’s core ethical values in their day-to-day operations and business affairs to protect CASB’s reputation.

The following are the key ABC standards that must be adhered to:

1.      Giving and Accepting of Gifts & Hospitality

CASB prohibits employees from offering, soliciting or receiving any gifts or hospitality in any form, to or from current or potential customers, vendors, agents and business partners, either directly or indirectly which may influence the employee’s judgment in a decision-making process or put the employee in a position of conflict. 

2.      Dealing with Government Officials

Any giving or receiving directly or indirectly of, kickbacks or gratuities to/ from government officials is not allowed. Due care and diligence must be exercised at all time when dealing with government officials or related associated persons. 

3.      Facilitation Payments

CASB prohibits any form of offering, giving or accepting any form (either in cash or anything of value) of improper payments such as bribes or kickbacks in exchange for business favors, information and favorable treatment. 

4.      Donations and sponsorships

CASB does not allow its business to be used as a channel for money laundering, terrorism financing or other criminal activities.  

5.      Recruitment of employees

CASB prohibits any form of employment opportunities, whether permanent or temporary in nature that is used as an inducement to obtain or retain an advantage in business. 

6.      Third-Party/ Business Associates Relationship

All employees are required to exercise due care and due diligence at all times when dealing with third-parties/ business associates and ensure their affairs do not involve any form of corrupt practices, perceived or actual. 

7.      Prohibit retaliatory action against employees

It is the responsibilities of all the employees, officers and directors of the company to prevent, detect, report any bribery and other forms of corruption.  Any employee who raises a concern in good faith will not suffer demotion, penalty or other adverse consequences from the company.

This policy will be communicated to all employees and directors of CASB. All employees and directors must read and understand CASB position on anti-bribery and anti-corruption.

Corruption risk assessment is conducted periodically to identify, analyses, assess and prioritize internal and external corruption risks. CASB to ensure regular monitoring and reviews are conducted to ensure appropriate controls and contingency measures are in place with appropriate and adequate training regarding anti-bribery and corruption compliance.

Effective from the date of this Policy, all CASB personnel confirm they have read, understood and will abide by this Policy. A copy of this confirmation shall be documented and retained by Human Resources Department.

Non-compliance with the policy may result criminal or civil penalties which will vary according to the offence. An employee acting in contravention of the policy will also face disciplinary action up to and including summary dismissal.