General Principles

All Employees shall, at all times in making any Business decision affecting KLWC, comply with the following principles: 

1. comply strictly to the provisions of the Act;
2. shall not participate or condone any acts or forms of Bribery;
3. the prevention, detection and reporting of any Gratification received, Bribery and other forms of corruption are the responsibility of all Personnel;
4. all Employees are required to avoid any activity that might lead to, suggest, imply or cause a breach of this Anti-Bribery and Anti-Corruption Policy or the Act; 
5. always exercise proper care and judgement;
6. avoid conflict of interest;
7. conscientiously maintain the highest degree of integrity and ethics;
8. comply fully with all applicable laws, regulatory requirements on Anti-Corruption and all regulations, procedures, and policies issued by KLWC;
9. KLWC adopts a no gifts policy, subject to certain limited exceptions as detailed in AC Policy;
10. notify the Audit Committee of KLWC as soon as possible if it is believed or suspected that a conflict with this Anti-Bribery and Anti-Corruption Policy has occurred, or may occur in the future, or if they have been offered any form of Gratification, Bribery, are asked to make one, suspect that this may happen in the future or believe that they are victim of another form of unlawful activity;
11. If any Third Party or external party is aware of any activity by any Personnel which might lead to, or suggest, a breach of this Anti-Bribery and Anti-Corruption Policy, they should raise their concerns to the Audit Committee of KLWC.

Gifts 

A. Providing Gift 

a) “Corporate gift” with the company’s name and logo and are of nominal/appropriate value such as diaries, table calendars, pens, notepads and plaques. “Festive or ceremonial gifts” are traditional treats or gifts customary to the occasion such as red packets (without cash or cash equivalent), oranges and dates. 

b) Corporate gifts, festive or ceremonial gifts may be given to our Business Partners or other parties provided it fulfills as of the following conditions: 

1. made for the right reason – it should be clearly given as an act of appreciation or common courtesy associated with festive seasons or other ceremonial occasions; 
2. Corporate Gifts not exceeding RM500 in a single receipt;
3. Do not have or are perceived to have, any effect on actions or decisions;
4. No expectation of any specific favour or improper advantages from the intended recipients; 
5. Gift to be done in an open and transparent manner; 
6. Independent business judgement of the intended recipients not affected;
7. Customary and lawful under the circumstances; 

When in doubt, the Employee is to consult the Audit Committee. 

B. Accepting Gift 

a) KLWC’s code of conduct require that all employees demonstrate the organisation’s commitment to treating all people and organisations, with whom we can come into contact or conduct business with, impartially. Our employees will demonstrate the highest standards of ethics and conduct in all matters when dealing with 

1. All vendors and suppliers, both existing and potential,
2. The customers and clients again, both existing and potential
3. Employee and potential employees
4. Independent contractors and agents of the company
5. Any individual or organization with whom they come into contact 

b) All employees must abide by the following no-gift policy requirements. Any exception to the gift policy may be made only with the permission of the Management or Audit Committee whichever is higher.

c) Any gift received must not be made with the intention to improperly influence the Business decision-making by a Third Party or Personnel to obtain or retain business or business advantage, or to reward the provision or retention of business or a business advantage, or in explicit exchange for favours or benefits towards KLWC or the Personnel. 

1. Gift or rewards to be received shall have the value of not more than RM500 per time and if it is necessary, the Company of Audit Committee shall be notified;
2. Any gift or rewards having the value of more than RM500 from third party must notify and report to Audit Committee immediately;
3. The gift received shall not include cash or a cash equivalent; If you are in doubt about the acceptability, the gift must be refused.

Hospitality and Entertainment 

a) Hospitality or Entertainment given or received in the form of cultural and sporting events is permitted without prior approval as long as it does not violate the provisions of this policy and is not more than a RM500. 

b) Entertainment events attended must always be ethically acceptable and not against applicable law and the Anti-Bribery and Anti-Corruption Policy. 

c) Any travel arrangement for government officials, business partners or customers must be pre-approved by Management. Reasonable meeting, travel or accommodation expenses are permitted as below: 

1. If KLWC is arranging a business-related arrangement for third party such as meeting, seminar or presentation. 
2. Any events or arrangement shall not be illicit, illegal or sexual in nature. 
3. Only for persons directly related to the business (e.g., not spouses, relatives or etc.)
4. Payments for all hospitality and entertainment must be made directly by KLWC to the service provider. Detailed and itemized receipt of such expenses must be submitted with the appropriate method for payment or reimbursement. 
5. A log of all entertainment received and given by KLWC employees must be maintained which include: 
   • The attendees by name
   • Attendees position in KLWC or other Company
   • Location/type of venue
   • Purpose of the meeting
   • The cost per attendee (estimated if not known)

SPONSORSHIP AND CHARITABLE DONATIONS

As part of KLWC commitment to contribute and give back to the communities where KLWC operates, KLWC provides such assistance in appropriate circumstances and in an appropriate manner. 

Employees and Directors must ensure that all donation and sponsorship by KLWC are not used to circumvent, avoid or evade the laws or regulatory requirements. More importantly, it shall not be used to facilitate corruption, illegal and money laundering activities. 

Providing Donations and Sponsorships

a) All request for donations and sponsorships by KLWC shall be directed to the Head of Internal Audit Committee and shall be carefully examined with appropriate due diligence by evaluating the request against the following criteria:

1. the objective of the donation and sponsorship does not contradict with the KLWC’s values;
2. the intended recipient is a legitimate organisation and proper due diligence/background checks have been conducted;
3. the intended recipient does not have affiliation with a Public Body (defined under MACCA); and
4. there is no risk of a perceived improper advantage for KLWC. 

b) If the request meets the above criteria and it is reasonably ascertained to be legitimate in nature, the Head of Internal Audit Committee shall proceed to recommend the request for approval accordingly to the Approval Matrix for non-operating expenses. 

c) Once donation or sponsorship has been made, KLWC shall undertake necessary measures to validate the carrying out of the intended utilization of the donation or sponsorship, and where possible, make note on whether the objectives of the donation or sponsorship has been achieved. 

d) A trail of documentary evidence relating to donations and sponsorships by KLWC (including all expenses uncured for donations and sponsorships) shall be compiled and kept in database within the relevant business unit of KLWC. 

POLITICAL CONTRIBUTIONS 

KLWC has no political affiliation and will not make any political contributions or favours. All employees and Directors are strictly prohibited from making political donations (to political parties, politicians and political campaigns) for or on behalf of KLWC. 

While Employees, Directors and Business Associates are not prohibited from making personal political donations or contributions, those donations or contributions must never be associated with the Group and must always be made in Employees’, Directors’ and Business Associates’ own personal capacity. 

FACILITATION PAYMENTS 

Facilitation payments are defined as “any facilitating payment or expediting payment to a foreign official, political party, or party official the purpose of which is to expedite or to secure the performance of a routine governmental action.” Employees should ensure that these facilitation payments are not paid. 

RECRUITMENT OF EMPLOYEES

Recruitment 

KLWC will conduct its recruitment practices in fair and transparent manner. This avoids distortions in the recruiting process that lead to risks with unethical or unsuitable candidates being selected. KLWC will demonstrate that its recruitment processes are untainted by bribery, favoritism or nepotism. 

Appropriate due diligence will be applying in selecting recruits, especially senior management and employees particularly those to be placed in department or aspect of operational functions vulnerable to bribery and corruption. 

Employment Contract 

KLWC expects the adherence to the provisions, principles and standard of this Policy by Employees and requires Employees to attest in writing that they have read, understood and will observe the provisions, principles and standard of this Policy. This attestation will be done by filling up the Employee Declaration Form or any other form as provided by the Head of People and Culture or as and when they are taking up a new position in KLWC or the Integrity and Background Declaration for Employees, which shall be signed and submitted to KLWC prior or during the official appointment or new Employees by KLWC. 

Existing Employees must declare any conflict of interest in the same way upon this Policy being disseminated to them. 

The terms and conditions of the employment contract should contain appropriate provisions on compliance with Anti-bribery and Anti-corruption requirements of KLWC, the right to termination and disciplinary action for non-compliance and such other requirements as KLWC may from time to time consider appropriate in relation to Anti-Bribery and Anti-Corruption. 

TRAINING AND COMMUNICATION 

a) KLWC shall conduct an awareness programme for all its Personnel on KLWC’s position regarding Anti-bribery and corruption, integrity and ethics. 

b) Training shall be provided on a regular basis, in accordance with the level of Bribery and Corruption risk related to the position. Training should be provided to Personnel who are: 

1. new to KLWC;
2. appointed to or currently holding an Exposed Position. 

c) All training materials and communicated information as well as the attendance record of internal training sessions shall be compiled and kept by the HR Department.  

BUSINESS PARTNERS AND THEIR CONDUCT

KLWC’s dealings with Third Party, shall be carried out in compliance with the ACT and all relevant local and foreign laws and consistent with the values and principles of this Anti- Bribery and Anti-Corruption Policy. As part of this commitment, all forms of Bribery and Corruption are unacceptable and will not be tolerated. 

Due Diligence should be carried out with regards to any Third Party intending to act on KLWC’s behalf as an agent or in other representative roles, to ensure that the entity is not likely to commit an act of bribery or corruption in the course of its work with KLWC. 

KLWC expects that all and any Third Party acting for or on its behalf to share the principles, values and ethical standards to ensure that their actions does not implicated KLWC legally and tarnish the KLWC’s reputation for being involved with Bribery and Corruption. 

KLWC shall inform any Business Partners of KLWC’s Anti-Bribery and Anti-Corruption Policy and with effect from the date of this Policy, all Business Partners must submit an Anti-Corruption Declaration or confirmation in similar terms prior to on-boarding as KLWC’s service provider.