Anti-Bribery and Corruption (ABC) Policy

  1. POLICY STATEMENT
    2.

    BELIANEMAS SYNERGY SDN. BHD (herewith BES) is committed to comply with all regulatory conditions and anti-corruption standard requirements by:

    1. Creating a bribery-free business environment and zero tolerance towards briber.
    2. Complying with laws, regulations and guidelines against bribery practices.
    3. Upholding anti-bribery and anti-corruption principles in all business dealings and interactions with external parties, including business associates, government agencies and stakeholders.
    4. Establishing an Anti-Bribery Management System (ABMS) and continuously improving its implementation to ensure compliance with ABMS requirements.
    5. Encouraging staff and public to report any suspicious corruption activities by providing a suitable channel of communication and ensuring information is treated appropriately.
    6. Establishing an anti-bribery compliance team to be responsible for the anti-bribery compliance of the company.
    7. Subjecting all staff who do not comply with this anti-bribery policy to disciplinary actions in accordance with the Statutory Bodies (Conduct and Discipline) Ordinance, 2004 and shall report the alleged misconduct to the relevant authorities.
    8. Continually communicate anti-bribery policy to all employees and business associates.

  1. DEFINITION OF BRIBERY AND CORRUPTION
    2.

    Generally, bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal, unethical or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

  1. OBJECTIVE
    2.  ABMS Objectives Table
    No ABMS Objectives Measurement Method Target Responsibility
    1. To promote a zero-tolerance culture toward bribery Internal audit report At least one internal audit every 12 months Anti-bribery compliance team
    2. To strengthen due diligence processes for business associates and high-risk positions Number of registered new suppliers & subcontractors vs due diligence report 100% due diligence check for new business associates before engagement Anti-bribery compliance team
    Number of recruited high-risk positions vs. due diligence report 100% due diligence check for high-risk positions before recruitment
    3. To strengthen anti-bribery commitment from business associates Training records 50% registered subcontractors or suppliers attend anti-bribery training Anti-bribery compliance team
    4. To improve the anti-bribery culture within the organization Training records 50% staff attend anti-bribery training Anti-bribery compliance team
  1. APPLICABILITY
    2.

    This Policy applies to all Directors, officers, employees (full and part time) and temporary workers of the company.

    Each Director and employee have a duty to read and understand the Policy. Violation of any of the Policy’s provisions may result in disciplinary action, including termination of employment.

    If any Director requires further clarification on the Policy, the Director may liaise with the Managing Director, as for employees, they may refer or highlight any concerns to their immediate superior or head of division/department.

  1. GUIDANCE ON COMMON FORMS OF BRIBERY AND CORRUPTION
    • Gift and Hospitality
      •

      The test to be applied is whether in all the circumstances the gift is reasonable and justifiable rather than lavish and extraordinary, bearing in mind that what may normally be viewed as small or insignificant in some countries can be of significant value to another. The intention behind the gift should always be considered and nothing should be specifically expected or demanded in return.

      All employees of “THE COMPANY” are expected to immediately record the acceptance of a gift worth above RM500.00 for submission to the Head of Department who will then decide whether to approve the acceptance of the gift or require it to be returned.

      In any event of conflict of interest, the Head of Department must not approve the acceptance of such a gift and must politely return such a gift with a note of explanation about “THE COMPANY”’s No Gift Policy.

      The Head of Department may approve the acceptance of the said gift but must determine the treatment of the gift whether to:

      1. Donate the gift to charity; or
      2. Hold it for display in the Department; or
      3. Share it with other employees in the Department; or
      4. Permit it to be retained by the employee.

      In doing so, the Head of Department is expected to exercise due care and proper judgment considering pertinent circumstances including the character of the gift, its purpose, the position/seniority of the person providing the gift, the business context, reciprocity, applicable laws, and cultural norms.

      Exceptions to the No Gift Policy

      Although generally “THE COMPANY” practices a "No Gift Policy," there are certain exceptions to the general rule whereby the receiving and provision of gifts are permitted in the following situations:

      1. Exchange of gifts at the company-to-company level (e.g. gifts exchanged between companies as part of an official company's visit/courtesy call and thereafter the said gift is treated as Company’s property)
      2. Not a cash or a cash equivalent such as vouchers, discounts, coupons, commissions, shares, etc;
      3. Considering the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and
      4. Given openly, not secretly.
    • Facilitation Payments

      • Facilitation payment is defined as payments made to secure or expedite the performance by a person performing a routine or administrative duty or function. Offering, promising or requesting facilitation payments is just as prohibited as actually paying or receiving facilitation payments. Facilitation payments need not involve cash or other financial assets; they can be any sort of advantage with the intention to influence them in their duties. “THE COMPANY” prohibits accepting or obtaining, either directly or indirectly, facilitation payments from any person for the benefit of the employee himself or for any other person who is subject to “THE COMPANY”. The reason underlying this prohibition is that facilitation payment is seen as a form of bribery and corruption. All persons subject to the “THE COMPANY” must not offer, promise, give, request, accept or receive anything which might reasonably be regarded as a facilitation payment. If you receive a request or if you are offered facilitation payments, you must report it to your Head of Department.

    • Third Parties and Agencies

      • Third Party(ies) means any individual or organization that an employee or associates can come into contact during the course of his/her work or engagement for or with “THE COMPANY” including but not limited to, the existing or potential customers, suppliers, consultants, agents and its representatives, contractors, external companies and any other stakeholders with whom a business relationship, whether current, prospective or historic exists.

    • Political Contribution

      • "THE COMPANY” does not make any contributions or donations, whether in the form of monetary or in-kind, to political parties, political party officials, or candidates for political office except in accordance with the laws and with the written authorization of the Managing Director. Top management and employees shall be deemed to be acting in their own personal capacity and not on behalf of the company in the event that they have contributed to any political parties or candidates without any appropriate authorization or approval.

    • Corporate Social Responsibility (CSR), Sponsorship And Donations

      • “THE COMPANY” is committed to cultivating a strong relationship with the local communities in which we live and work by contributing to the well-being of the people and the nation. It is, however, important that all Corporate Social Responsibility (CSR), sponsorships, and donations are made in accordance with “THE COMPANY” policies and receive prior authorization from “THE COMPANY”.

      Corporate Social Responsibility (CSR)

      As part of our commitment to CSR and sustainable development, “THE COMPANY” will contribute to Social Investment activities in the countries where we have operations. However, such requests must be carefully examined for legitimacy and not be made to improperly influence a business outcome. The proposed recipient must be a legitimate organization, and appropriate due diligence must be conducted, in particular to ascertain whether any public officials are affiliated with the organization. If you are in any doubt as to whether a charitable contribution or social benefit is appropriate, consult the Anti-Bribery Compliance Team for assistance.

      Sponsorships and Donations

      As set out in the ABC Policy, employees must ensure that all sponsorships and donations are not used as a subterfuge for bribery or used to circumvent, including in particular, the prohibition on bribery. “THE COMPANY” needs to be certain that donations to foreign-based charities or beneficiaries are not disguised illegal payments to government officials and must ensure that the charity does not act as a conduit to fund illegal activities in violation of international anti-money laundering, anti-terrorism and other applicable laws.

      “THE COMPANY” will conduct CSR or Donations in the project area when required and not during the election period.

  1. RECORD-KEEPING
    2.

    “THE COMPANY” must ensure and keep all financial records, all expenses and claims relating to entertainment, gifts and have appropriate internal controls in place which will be the evidence for any payments made to third parties.

  1. COMPLIANCE TO THE LAW
    2.

    The Company will comply with all applicable laws, rules and regulations of the Governments, commissions and exchanges in jurisdictions within which the Company operates. Directors and employees are expected to understand and comply with the Malaysian Anti-Corruption Commission Act 2009 (including any amendment thereof). The Group reserves the right to report any actions or activities suspected of being criminal in nature to the police or other relevant authorities.

  1. REPORTING OF VIOLATIONS OF THE POLICY
    2.

    Any Employee who knows of, or suspects, a violation of the Policy, is encouraged to whistle blow or report the concerns through the mechanism set out under the Company’s Whistle Blowing Policy. It is important that you tell the Chairman of Whistleblowing Committee as soon as possible if you are being offered a bribe. The provision, protection and procedure of the Whistle Blowing Policy for reporting of the violations of the Policy are available on the Company’s website. No individual will be discriminated against or suffer any sort or manner of retaliation for raising genuine concerns or reporting in good faith on violations or suspected violations of the Policy. All reports will be treated confidentially.

  1. PENALTY (SECTION 24 MALAYSIAN ANTI-CORRUPTION COMMISSION ACT 2009 )
    2.

    Failure to report an act of giving and offering bribes is an offence under the section above-mentioned. Corruption is punishable by imprisonment not exceeding 20 years and a fine of not less than five (5) times the sum or value of the gratification that is subject matter of the offence, where gratification is capable of being valued or is of a pecuniary nature, or RM10,000 whichever is higher.

  1. REVIEW OF THE POLICY
    2.

    The ABC Policy is subject to review and will be updated and revised accordingly. Amendments to the policy will be reviewed during the Management Review Meeting. Notwithstanding the periodic review, amendments to the policy can be made anytime, as and when required. Changes or amendments to the policy will be tracked using the Revision History Sheet.

APPROVED BY THE BOARD OF DIRECTORS ON 06 JANUARY 2026