Anti-Bribery And Corruption Policy

1.	Objective
	Engaging in bribery and corrupt practices is detrimental to the stakeholders of Melati Ehsan Holdings Berhad (“Melati” or “the Group”). Therefore, the Board has defined this Anti-Bribery and Corruption Policy (“ABC Policy”) outlining the measures to mitigate the bribery and corruption risk as well as the procedures to uphold the ethical business standard against bribery. It is the aim of the Group to ensure that this Policy will guide our staff members, employees and business associates in following and promoting a corruption and bribery-free business environment. All directors, members of management and employees should adhere to this Policy and communicate it to our business associates. Staff members, employees and business associates who are aware of, or suspect a violation of the Policy shall report the violations by following the Group’s reporting procedures in the Whistleblowing Policy.

2.	The Anti-Corruption Measures
	In order to manage and mitigate the corruption risks exposure, the Group:
	i.	States publicly its commitment to anti-corruption;
	ii.	Communicates and publishes the ABC Policy in the corporate website;
	iii.	Imposes business associates’ contractual obligations in complying with anti-bribery regulations;
	iv.	Establishes the policies for ethical business responses for gift, hospitality, entertainment, donation, sponsorship and facilitation payments;
	v.	Implements financial and organisational controls and procedures to scrutinise and approve payments;
	vi.	Assesses and updates corruption risk assessment annually and reports to the Board;
	vii.	Conducts annual management review and confirmation of the adequacy of the corruption risk mitigation measures based on the respective departmental risk documentation;
	viii.	Performs internal audit review of the management corruption risk mitigation actions;
	ix.	Discloses the Group’s commitment, measures and performance to prevent corruption in Annual Report; and
	x.	Establishes a whistleblowing channel for stakeholders to raise concerns on actual or suspected corruption incidents.

3.	Gift
	Gift giving and receiving are prohibited except for the following situations:
	i.	Gift giving or receiving within the Group’s permitted amount during festive celebrations and occasions;
	ii.	Gift exchange as part of a public presentation or ceremony; or
	iii.	Gift bearing a company’s logo, such as corporate souvenirs.
	In cases where gifts are to be offered or received are more than the prescribed value, directors, employees, family members or agents working on behalf of the Group are required to record the details of the gift in “Hospitality, Entertainment & Gifts Giving / Received Declaration Form” and obtain pre-approval from an Executive Director. However, none of the Executive Director shall approve gift to be offered and received by him/herself and shall seek approval from another Director. If approval is not obtained, the gift must be returned with a note of explanation about the Group’s Gift Policy; or donate the gift to a charity.

4.	Hospitality & Entertainment
	Corporate hospitality and entertainment include hosting of functions and provision of accommodation for business partners. In ordinary course of business, employees may provide or receive hospitality and entertainment to/ from business partners within the Group’s permitted amount. If hospitality and entertainment to be offered are more than the permitted amount, the details and reason of providing or receiving the hospitality and entertainment shall be documented in “Hospitality, Entertainment & Gifts Giving/ Received Declaration Form” and approved by an Executive Director or other Executive Director, if he/she is the offeror or recipient.

5.	Referral Payment
	No directors, officers, management and employees or their immediate family members shall request or receive any referral fee, commission or benefit from our business associates on personal capacity. The Group also prohibits referral payment to government officials and individuals representing regulatory authorities. Referral payment for securing customer and employee shall not be more favourable than the market and industry practices.

6.	Facilitation Payment
	All directors, management and employees of the Group should follow strict compliance of all internal and external procedural requirements and shall not breach any procedural requirements to expedite and facilitate application and approval processes for business dealings and transactions.

7.	Sponsorship
	Sponsorship such as sponsoring for sport competitions, functions and any other events or activities is part of the Group’s corporate social responsibility (“CSR”). All sponsorship provided should be approved by the Group Executive Chairman and supported with documentation.

8.	Donation
	Donations are monetary benefits or equivalent, equipment, or other benefits or contribution to a fund and charity causes are part of our Group’s CSR. The Group will only donate to government agencies, non-governmental organisations, charitable organisations, temples, educational institutions, and associations for their public donations campaigns. Similar with sponsorship, all donations made should be approved and documented.

9.	Review of Anti-Bribery and Corruption Framework
	The Board shall review the Anti-Bribery and Corruption Framework at least once every three (3) years and ensure that its Policy remains consistent with and relevant to current regulation requirements and corruption risk exposure. Amendments to this Policy shall be approved by the Board.