1. Objective

Engaging in bribery and corrupt practices are detrimental to the stakeholders of Melati Ehsan Holdings Berhad (“Melati” or “the Group”). Therefore, the Board has defined this Anti-Corruption Measures and Policies (“ACMP”) outlining the anti-corruption measures to mitigate the corruption risk of the Group as well as the policies governing the ethical business responses to bribery. It is the aim of the Group to ensure that this ACMP will provide the right direction for our staff members, employees and business associates to follow and to promote a corruption and bribery free business environment.

All directors, members of management and employees should adhere to this ACMP and also communicate to our business associates to adhere to this ACMP. Staff members, employees and business associates who are aware of, or suspect a violation of the ACMP shall report the violations in accordance with 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 shall:

  1. State publicly its commitment to anti-corruption;
  2. Communicate and publish the ACMP in the corporate website to all parties in the supply chain including non-controlled persons and entities;
  3. Impose contractual obligations in complying with anti-bribery regulations on non-controlled persons or entities for not committing corrupt acts;
  4. Define the Group’s policies for ethical business responses for gift, hospitality, entertainment, donation, sponsorship and facilitation payments;
  5. Review the compliance and effectiveness of the Group’s anti-corruption policies; the internal financial and organizational controls and procedures; and implement on-going improvements as appropriate;
  6. Perform periodic bribery risk assessment with the results reported to a Board-level committee;
  7. Disclose the Group’s commitment and measures to prevent corruption in Annual Report; and
  8. Establish a reliable whistleblowing channel, for stakeholders to raise concerns on actual or suspected corruption incidents.
3. Gift Policy

Gift giving and receiving are prohibited except for the following situations:

  1. Gifts value not more than RM1,000 per person for Director and RM500 per person for other staff members and employees (the “prescribed value”);
  2. Exchange of gifts of equivalent value as part of a public presentation or ceremony; or
  3. Gifts bearing a company’s logo and are of nominal value such as corporate souvenirs.

In cases where gifts 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 Policy

Corporate hospitality and entertainment include hosting of functions and provision of accommodation for business partners.

In ordinary course of business, directors, management and employee may provide or receive hospitality and entertainment to /from business partners within the amount of RM500 per person (the “prescribed limit”).

If hospitality and entertainment to be offered are more than the prescribed 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.

5. Referral Payment Policy

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 payments for securing projects and business opportunities shall not exceed 3% of the value of the underlying agreement or arrangement. Any referral payment above this percentage shall be subject to Group Managing Director’s approval.

On the other hand, referral payment for securing customer and employee shall not be more favorable than the market and industry practices.

6. Facilitation Payment Policy

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 application and approval processes for business dealings and transactions.

On the other hand, all directors, management and employees are prohibited to accept payments and benefits for facilitation from any business associates or agents.

7. Sponsorship Policy

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 Managing Director and supported with documentation.

8. Donation Policy

Donations are monetary benefits or equivalent, equipment, or other benefits or contribution to a fund and charity causes as part of our Group’s CSR.

The Group will only donate to government agencies and non-governmental organisations for recreational and religious activities and events, charitable organisations, schools and associations.

Similar with sponsorship, all donations made should be approved and documented.

9. Review of ACMP

The Board shall review this ACMP at least periodically or at least once every three (3) years and ensure that this policy remains consistent with and relevant to current regulation requirements and corruption risk facing the Group. Amendments to be made on this policy shall be approved by the Board with a formal resolution.