1. Purpose

Sg. Rambai Holdings Sdn Bhd and its group of companies (the “Group”) is committed to conducting its business ethically and in compliance with all applicable laws and regulations regarding anti-bribery and corruption. This policy outlines the Group’s stance against bribery and corruption and provides guidance to employees on how to recognize and deal with bribery and corruption issues.

2. Scope

This policy applies to all employees, directors, officers, agents, consultants, and any other third parties acting on behalf of the Group.

3. Policy Statement

The Group has a zero-tolerance approach to bribery and corruption. Employees and associated persons must not engage in any form of bribery or corruption, whether directly or indirectly.

4. Definition of Bribery and Corruption

• Bribery: Offering, giving, receiving, or soliciting something of value as a means to influence the actions of an individual in a position of power or authority.
• Corruption: Abuse of entrusted power for private gain.

5. Prohibited Activities

• Offering, giving, or receiving bribes or anything of value to/from any person or entity with the intention of obtaining or retaining business or securing an improper advantage.
• Making facilitation payments to expedite or secure the performance of a routine governmental action.
• Offering or accepting gifts, hospitality, or entertainment that could be perceived as a bribe.

6. Gifts and Hospitality

• Employees must not offer or accept gifts, hospitality, or entertainment that could influence, or appear to influence, the outcome of business transactions or relationships.
• All gifts and hospitality must be reported and recorded in accordance with the Group’s procedures.

7. Third Parties

• The Group expects all third parties acting on its behalf to comply with this policy.
• Due diligence must be conducted before engaging with third parties to ensure they have a reputation for ethical conduct.
• Third parties must be informed of the Company’s anti-bribery and corruption policy and their obligation to comply with it.

8. Responsibilities

• Employees: Must read, understand, and comply with this policy. Employees must report any concerns or suspicions of bribery or corruption to their immediate supervisor or through the Company’s whistleblowing channel.
• Management: Responsible for ensuring that the policy is implemented effectively and that all employees are trained on anti-bribery and corruption measures.
• Compliance Officer: Responsible for monitoring compliance with this policy and conducting regular audits.

9. Reporting and Whistleblowing

• Employees are encouraged to report any concerns or suspicions of bribery or corruption through the Group’s whistleblowing channel without fear of retaliation.
• The Group will investigate all reports of bribery and corruption promptly and confidentially.

10. Consequences of Non-Compliance

• Employees who violate this policy will face disciplinary action, which may include termination of employment.
• The Group reserves the right to terminate its relationship with any third parties who breach this policy.

11. Training and Communication

• All employees will receive training on anti-bribery and corruption as part of their induction and on a regular basis thereafter.
• The policy will be communicated to all employees, third parties, and stakeholders.

12. Review and Monitoring

• This policy will be reviewed annually and updated as necessary to ensure its effectiveness.
• The Compliance Officer will monitor the implementation of this policy and report to the Board of Directors.