Anti-Bribery and Corruption Policy

Introduction

EFS Revision Energy Sdn Bhd (Company No. 201301032646 (1062475-M) (hereinafter referred to as “the Company”) is committed to conducting its business with the highest standards of ethics, integrity, and transparency. As part of this commitment, the Company has adopted this Anti-Bribery Policy to prohibit any form of bribery, corruption, or unethical conduct in its operations. This policy applies to all employees, contractors, agents, and representatives of the Company (collectively referred to as “Staff”).

Policy Statement

The Company strictly prohibits any form of bribery, whether direct or indirect, including offering, giving, receiving, or soliciting bribes. This policy applies to all business activities and transactions conducted on behalf of the Company, both in Malaysia and abroad. The Company is committed to complying with all applicable anti-bribery laws and regulations in Malaysia.

Compliance with Malaysian Laws

The Company will ensure that its anti-bribery practices and procedures are in compliance with the laws of Malaysia, including but not limited to:

a. Malaysian Anti-Corruption Commission Act 2009 (MACC Act)
b. Penal Code (Act 574)
c. Companies Act 2016
d. Other relevant legislation and regulations related to bribery and corruption in Malaysia

Prohibited Conduct
  • Bribery and Corruption

No Staff shall directly or indirectly engage in any form of bribery or corrupt practices. This includes offering, promising, giving, receiving, or soliciting anything of value, whether monetary or non-monetary, to or from any individual, private or public entity, or government official with the intent to influence business decisions or gain an unfair advantage.

  • Facilitation Payments

Facilitation payments, also known as “grease payments,” are small payments made to expedite routine governmental actions or services to which the Company is entitled. The Company strictly prohibits the use of facilitation payments, as they are illegal under Malaysian law.

  • Gifts, Hospitality, and Entertainment

The Company recognizes that legitimate business relationships may involve the exchange of gifts, hospitality, or entertainment. However, such activities must be reasonable, proportionate, and not intended to influence the recipient to obtain an improper advantage. Staff must adhere to the Company’s Gifts, Hospitality, and Entertainment Policy, which sets out clear guidelines for the giving and receiving of such items.

Certain types of gift, hospitality and entertainment are not permissible. As a guiding principle, the following gifts, hospitality and entertainment are strictly prohibited:

  1. Any gift, hospitality or entertainment that is illegal or in breach of and laws, regulations or rules;
  2. Any gift, hospitality or entertainment offered to a Government Official to facilitate or expedite a routine procedure;
  3. Gifts, hospitality or entertainment involving parties currently engaged in a tender or competitive bidding process;
  4. Gifts made in cash or cash equivalent i.e. anything that can be easily converted to cash;
  5. Any hospitality or entertainment that are sexually oriented;
  6. Any gift, hospitality or entertainment that is a “quid pro quo”, i.e. something offered in return of something else such as business advantage; and
  7. Any gift, hospitality or entertainment that is paid for personally to avoid having to declare or seek approval for.

It is pertinent to bear in mind the broader context in which the gift, hospitality and/or entertainment offered or received. Any gift, hospitality or entertainment that may appear or be perceived as influencing or compromising the judgment or objectiveness shall not be offered or received.

  • Political Contributions

Staff shall not make any political contributions on behalf of the Company without the prior written approval of the appropriate management authority. The Company will not provide any funds or assets to any political party, candidate, or campaign with the expectation of influencing political decisions.

Reporting and Non-Retaliation

The Company encourages Staff to report any actual or suspected breaches of this Anti-Bribery Policy promptly. Reports can be made to the designated compliance officer or through the Company’s confidential reporting channels. The Company is committed to thoroughly investigating all reports and will take appropriate action, including disciplinary measures, against individuals found to have violated this policy.

The Company strictly prohibits any form of retaliation against individuals who make reports in good faith. Staff members who report concerns or participate in investigations will be protected from any adverse employment actions or reprisals.

Training and Communication

The Company will provide training and awareness programs to ensure that all Staff understand their obligations under this Anti-Bribery Policy and relevant Malaysian laws. The policy and related procedures will be communicated to Staff through various channels, including employee orientations, training sessions, and regular updates.

Record Keeping and Monitoring

The Company will maintain adequate records to demonstrate compliance with this Anti-Bribery Policy. These records may include training records, due diligence documentation, and records of gifts, hospitality, and entertainment. The compliance officer or designated personnel will periodically review and monitor the effectiveness of the policy and associated procedures.

Trademarks and Copyrights

All trademarks and copyrights appearing on this website are the property of their respective owners. Nothing on this website shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service or mark displayed on this website without the owner’s prior written consent, except as otherwise stated.

Consequences of Non-Compliance

Any Staff found to have violated this Anti-Bribery Policy may be subject to disciplinary action, up to and including termination of employment or contract, and potential legal action as per applicable laws in Malaysia.