1. INTRODUCTION

2. DEFINITIONS AND INTERPRETATIONS

2.1 For the purpose of this Policy:

“Employee” means any person employed by the Company (executives, directors, managers, staff, engineers, wiremen) including full-time, part-time, contract, temporary, and interns.

“Business Associate” means any third party acting on behalf of or for the benefit of the company, including but not limited to agents, consultants, contractors, subcontractors, distributors, brokers, partners, and professional advisors.

“Bribe / Gratification” means any payment, gift, loan, fee, reward, service, employment offer, or advantage of any kind (monetary or non-monetary) offered, given, or received to influence a decision, obtain an improper advantage, or reward favourable treatment.

Includes: in the form of monetary, of monetary value, employment and non-monetary value.

Example (but not limited to): Cash, loan, donation, property, gifts, travel, entertainment, discounts, promises of future employment, use of corporate service and favours.

“Corruption” means the abuse or misuse of entrusted power, position, or authority for personal gain or to obtain an improper advantage for oneself or another party, whether directly or indirectly.

 “Facilitation Payment” means a payment made to a public official to speed up or secure routine government action that should have been performed in the ordinary course without any payment. This is strictly prohibited.

Example of Facilitation Payment (included but limited to):

i.Granting permit, license or other official documents
ii.Expediting inspection, certification or approval of application
iii.Facilitating customs clearance procedures

“Public Official” means any officer, employee or agent of a government, ministry, department, agency or state-owned entity, including family members or associates of such persons.

“Red Flag” means a warning sign or indicator suggesting a higher risk of bribery or corruption (e.g., unusual payment requests, refusal to sign contracts, lack of transparency, requests for payments to personal accounts).

“Reasonable Value” means a value that is modest, customary, and proportionate to the occasion, generally not exceeding RM400.00 (Ringgit Malaysia: Four Hundred Only) per instance, unless explicitly approved under defined exceptions.

“Minimal Value” (for interactions with Public Officials) means not exceeding RM250.00 (Ringgit Malaysia: Two Hundred and Fifty Only), limited to branded corporate items or modest refreshments.

“Legitimate Business Purpose” means a genuine business reason such as promoting products, building professional relationships, or education — not an attempt to influence decisions improperly.

“Tender Process” means open invitation to all qualified parties to submit proposals.

3. SCOPE AND APPLICATION

3.1 This Policy applies to all Employees and Business Associates. Directors bear the ultimate responsibility for ensuring adherence.

3.2 This Policy covers all jurisdictions where the Company operates. All individuals acting on behalf of the Company must ensure their conduct aligns with this Policy regardless of local customs or practices.

3.3 Subsidiaries, joint ventures and entities where the Company holds controlling interest must adopt this Policy or equivalent standards. For non-controlled partnerships, the Company will require contractual warranties regarding anti-bribery compliance.

3.4 This Policy applies to all business activities including sales, procurement, tendering, government liaison and financial transactions.

4. STANDARDS OF CONDUCT

4.1 All individuals covered by this Policy must:

• Act honestly, fairly and transparently in all dealings.
• Avoid any situation that creates or appears to create, a conflict of interest.
• Refuse any request for bribes or improper payments, whether made directly or indirectly.
• Never offer or accept anything that could be deemed an attempt to influence business outcomes improperly.
• Seek guidance from Head of Department or the Compliance Officer if unsure about any situation.

5. GIFTS, HOSPITALITY, AND ENTERTAINMENT

5.1 Core Principle: These are acceptable only if they are reasonable, proportionate, transparent, and made without improper intent.

5.2 Rules for Giving or Offering

• Must serve a Legitimate Business Purpose.
• Must be of Reasonable Value [generally ≤ RM 400.00 (Ringgit Malaysia: Four Hundred Only)] 
• Anything above this limit requires written approval from the Head of Department (HOD) or Compliance Officer, with full justification documented.
• Example of reasonable gifts: Tickets to events or similar functions attended together with business partners, as well as modest items such as pens, calendars, and small promotional merchandise.
• Example of unreasonable gifts: The Company is currently evaluating and selecting a new supplier, and you are involved in the assessment of suppliers participating in the tender process. During the negotiation period, one of the suppliers offers you concert tickets. This is considered an unreasonable gift as it is unrelated to legitimate business activities and is offered during a sensitive decision-making period. Therefore, the gift must not be accepted.
• Must be appropriate in context and frequency; not offered during active tender, negotiation, or regulatory approval phases.
• Prohibited: Cash or cash equivalents (vouchers, bonds), gifts of excessive value, or items intended to influence decisions.
• For Public Officials: Value must be ≤ RM250.00 (Ringgit Malaysia: Two Hundred and Fifty Only), corporate-branded items preferred, and approved in advance.

5.3 Rules for Receiving

• You may only receive items of reasonable value that are customary in business culture and do not create an obligation.
• You must declare all gifts received valued above RM400.00 (Ringgit Malaysia: Four Hundred Only) using the official Gifts s Hospitality Declaration Form within 3 working days.
• If refusal to accept would cause serious offense or harm business relations, you may accept the item and immediately surrender it to your HOD or Compliance Officer for official handling.
• Prohibited: Accepting cash, excessive entertainment, or anything given in exchange for favourable treatment.

5.4 Approval s Record Keeping

• All gifts and hospitality provided by the Company must be approved in advance and recorded in the central Gifts s Hospitality Register.
• Declarations must be retained for a minimum of 7 years.

6. DONATIONS, SPONSORSHIPS, AND CHARITABLE CONTRIBUTIONS

6.1 All contributions must:

• Be approved only by the CEO or Board of Directors; no delegation of this authority is permitted.
• Be made exclusively for social, charitable, or community purposes, with clear objectives and public benefit.
• Be paid directly to registered, legitimate organizations (verified via official registries such as ROS or Companies Commission).
• Be fully transparent, recorded publicly if required, and supported by receipts and documentation.
• Undergo risk assessment to ensure no links to Public Officials or improper influence.

6.2 Strictly Prohibited:

• Contributions made to obtain or retain business, licenses, or regulatory favors.
• Payments to individuals, unregistered entities, or organizations with unclear ownership.
• Payments made in cash or to offshore/unverified bank accounts.

7. FACILITATION PAYMENTS

7.1 POLICY: ZERO TOLERANCE.

7.2 Facilitation payments, regardless of amount or local custom, are classified as bribes and are strictly forbidden. No exceptions.

7.3 If an Employee is pressured or coerced to make such a payment, they must refuse clearly and immediately report the incident to their HOD and the Compliance Officer.

7.4 Any payment made under duress must be documented in detail (date, amount, person involved, circumstances) and reported immediately; it will not be treated as a breach provided refusal was clear and the report was timely.

8. INTERACTIONS WITH PUBLIC OFFICIALS AND GOVERNMENT DEALINGS

8.1 Interactions with Public Officials carry the highest risk and require enhanced scrutiny and formal approval.

8.2 Must be of minimal value (≤ RM250.00).

• Corporate-branded items are preferred over personal gifts.
• Must be modest, appropriate, and approved in writing by the Compliance Officer beforehand.
• Must never be offered during active regulatory approvals, licensing, or tender evaluations.
• Red Flags (must be reported immediately):
• Requests for payments to personal accounts or relatives.
• Requests for employment or contracts for family members.
• Demands for "commissions" or "fees" without valid invoices or purpose.
• Offers or requests that create an obligation or sense of indebtedness.

9. POLITICAL CONTRIBUTIONS

9.1 The Company is politically neutral.

9.2 Prohibited: Direct or indirect financial or non-financial support to any political party, candidate, or organization where the intent is to gain business advantage, licenses, or favourable treatment.

9.3 Personal political activities by Employees are permitted provided they are conducted outside work hours, do not use company resources and do not imply Company endorsement.

9.4 Any solicitation for political support or donations must be reported to the CEO immediately.

10. RECORD KEEPING AND FINANCIAL CONTROLS

10.1 All financial transactions must be recorded accurately, completely and clearly. NO "OFF-BOOK" ACCOUNTS OR TRANSACTIONS ARE PERMITTED.

10.2 Required standards:

• Supporting documents such as invoices, receipts, contracts, declarations and etc. must be retained for a minimum of 7 years.
• Expense claims related to business entertainment, travel, or third-party payments require detailed justification, proof of purpose, and approval at the correct level.
• Regular internal audits will verify compliance with financial controls.
• Deliberate falsification, omission, or misrepresentation of records is grounds for immediate termination and legal referral.

11. TENDER AND PROCUREMENT PROCESSES

11.1 The tender and procurement process must be conducted in a fair, open, and transparent manner, and must be free from influence or favouritism.

11.2 Mandatory controls include:

Conflict of Interest Declaration: All evaluation committee members and procurement employee must sign a declaration prior to the process.

Separation of Duties: Employees involved in defining requirements must not be solely responsible for the evaluation or approval process. Objective Criteria: Selection must be based strictly on price, quality, capability, compliance, and track record, and must not be influenced by gifts, favours or any improper benefit.Documentations: All decisions, evaluations, negotiations and changes must be fully documented and retained in a complete, accurate and auditable form.

11.3 Any offer of gifts or favours from a bidder or supplier must be reported immediately and may result in disqualification in the tendering process.

12. RISK ASSESSMENT AND MANAGEMENT

12.1 The Company shall conduct formal corruption risk assessments at least annually, or upon major changes in business, market, regulation or operating environment.

12.2 Assessments will identify risks in areas such as: procurement, sales, interactions with government, use of agents, and high-risk jurisdictions.

12.3 A risk register shall be maintained, updated regularly, and specific control measures shall be implemented for high-risk areas.

12.4 Risk assessments must be approved by the Compliance Officer and reviewed by the Board.

13. TRAINING AND AWARENESS

13.1 Mandatory Training:

All Employees: Will be given training upon work commencement and refresher training annually, including assessment of understanding.

Business Associates involved in sensitive functions must acknowledge receipt and understanding of this Policy or undergo equivalent training.

Failure to complete training or pass assessments will result in retraining and performance management.

14. ROLES AND RESPONSIBILITIES

14.1 Board of Directors / CEO

• Ultimate accountability for anti-bribery compliance.
• Approve this Policy and significant contributions.
• Ensure adequate resources, authority, and independence for the compliance function.

14.2 Compliance Officer / Designated Officer

• Ownership of the Policy; maintain and update it as laws or risks change.
• Compliance Officer will monitor implementation, investigate reports, and maintain all registers and records.
• Compliance Officer will provide advice, approve high-risk transactions and report to the CEO and Board regularly.

14.3 Heads of Departments

• Ensure staff understand and apply the Policy.
• Review and approve declarations and requests within their teams.
• Foster an ethical culture and lead by example.

14.4 All Employees

• Must read, understand and comply with this Policy.
• Attend required training.
• Declare relevant interests, gifts and potential conflicts.
• Report concerns immediately via proper channels.

15. DECLARATIONS AND CONFLICT OF INTEREST

15.1 Declaration: Every Employee must submit a Conflict-of-Interest Declaration Form disclosing any personal relationships, financial interests, ownership interests in a company, or positions that may give rise to an actual, potential, or perceived conflict with the Company’s interests upon commencement of employment, upon the implementation of this Policy, or whenever required by the Company.

15.2 Ad-hoc Declaration: Must be submitted as soon as the Employee becomes aware of any actual, potential or potential conflict of interest or when dealing with a party with whom the Employee has a personal relationship or connection.

15.3 Failure to disclose a conflict of interest is a serious breach of policy and will be subjected to disciplinary action

16. BUSINESS ASSOCIATES AND DUE DILIGENCE

16.1 Due Diligence: Before engaging any third party, the company shall conduct risk-based due diligence. Level of checks increases with risk (e.g., agents dealing with government require enhanced verification).

16.2 Standard Checks: Verify legal existence, reputation, ownership, and references.

16.3 Enhanced Checks: Source of funds, links to Public Officials, and anti-bribery policy verification.

16.4 Contractual Terms: All agreements must include an Anti-Bribery Clause requiring compliance, audit rights, and immediate termination rights for breach.

16.5 Monitoring: Business Associate are subject to periodic review and audit. Payments must match services rendered and be supported by valid documentation.

17. COMPLIANCE WITH LAW

17.1 This Policy is governed by the MACC Act 2006, Companies Act 2016, Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001, and relevant local laws.

17.2 Ignorance of the law or this Policy is not a defence.

17.3 Breach of law exposes the individual to criminal liability including fines and imprisonment. The Company may also face significant penalties, debarment from government contracts, and reputational damage.

18. REPORTING MECHANISM AND WHISTLEBLOWER PROTECTION

18.1 How to Report:

If you suspect or witness a violation, report it immediately via any of these channels:

• Whistleblower Hotline / Email: whistleblower@safetruck.co
• CEO: Mr. Wilson Yew (+6012-401 2223)
• CTO: Ms. Low Yin Yin (+6016-260 6367)
• Consultant: Mr. Ong Choon Seng (+6012-212 8428)
• Human Resource Managers: Ms. Juness Lee (+6016-6047266)

18.2 Requirements for Reports

• Made in Good Faith.
• Include facts, dates, names, and evidence where possible.
• Not malicious or frivolous.

18.3 Protection

• Confidentiality: Identity will be protected to the extent permitted by law.
• No Retaliation: The Company strictly prohibits any adverse action (demotion, harassment, termination) against anyone reporting a genuine concern. Retaliation is a disciplinary offense.
• Anonymous Reporting: The Company does not accept anonymous reports. Whistle-blowers must disclose their identity and provide relevant contact information to enable appropriate investigation and follow-up.

19. INVESTIGATIONS AND ENFORCEMENT

19.1 All reports will be assessed promptly. Valid concerns will result in a formal, impartial investigation, conducted or overseen by the Compliance Officer.

19.2 Outcomes & Sanctions

• Any confirmed breach of this Policy may result in disciplinary action, up to and including termination of employment or contract, where applicable.
• Legal action (civil recovery or criminal reporting) will be pursued where appropriate.
• Individuals are personally liable for legal penalties arising from their actions.
• Any false or malicious report made in bad faith may result in disciplinary action.

20. MONITORING, REVIEW, AND CONTINUOUS IMPROVEMENT

20.1 This Policy will be reviewed every 2 years, or sooner if required by changes in law, business structure, or risk profile.

20.2 Internal Audit will periodically test the effectiveness of controls and report findings.