Anti-Bribery and Corruption POLICY & STATEMENT

Teknos (M) Sdn. Bhd. has a long-standing commitment to conduct our business in compliance with applicable laws and regulations and in accordance with the highest ethical principles. This commitment helps to ensure our reputation for honesty, quality and integrity. Teknos (M) Sdn. Bhd. is bound by the laws of Malaysia, including the Malaysian Anti-Corruption Commission Act 2009, the Malaysian Anti-Corruption Commission (Amendment) Act 2018 and this policy is issued in line with the Guidelines on Adequate Procedures to Section 17A(5) of the MACC Act 2009.

We take a zero-tolerance approach to bribery and corruption and we are committed to acting professionally, fairly and with integrity in all business dealings by implementing and enforcing systems that ensure bribery and corruption is prevented. All employees (including temporary, contract staff, interns, directors), business partners and associates of Teknos (M) Sdn. Bhd., are responsible for reading, understanding and abiding by the policy, observing and upholding the same zero-tolerance position on bribery and corruption. Any engagement in such bribery or corrupt practices or activities will result in severe negative consequences including disciplinary action and prosecution under the MACC Act 2009.

Teknos (M) Sdn. Bhd.’s Anti-Bribery and Corruption Policy:

1. Teknos (M) Sdn. Bhd.’s policy is that bribery and corruption in all its forms as it relates to Teknos (M) Sdn. Bhd.’s activities is prohibited. 
2. Bribery and corruption may take the form of anything of value, such as money, goods, services, property, privilege, employment position or preferential treatment. Teknos Personnel and its business associates shall not therefore, whether directly or indirectly, offer, give, receive or solicit any item of value, in the attempt to illicitly influence the decisions or actions of a person in a position of trust within an organisation, either for the intended benefit of Teknos (M) Sdn. Bhd.  or the persons involved in the transaction.
3. The anti-bribery and corruption policy applies equally to its business dealings with commercial (‘private sector’) and Government (‘public sector’) entities. Even the possible appearance of bribery and corruption is to be avoided, in particular when dealing with Government officials.
4. Teknos (M) Sdn. Bhd. is committed to conducting its business ethically and in compliance with all applicable anti-bribery and corruption laws and regulations in every country where we do business. The anti-bribery and corruption policy therefore applies to all countries worldwide, without exception and without regard to regional customs, local practices or competitive conditions.
5. Teknos (M) Sdn. Bhd. shall conduct regular risk assessments to identify the bribery and corruption risks affecting the business, set anti-bribery and corruption objectives, and assess the effectiveness of the controls in achieving those objectives.
6. No Personnel or external party will suffer demotion, penalty or other adverse consequences in retaliation for refusing to pay or receive bribes, or participate in other illicit behaviour, even if such refusal may result in Teknos (M) Sdn. Bhd. losing business or experiencing a delay in operations.
7. Personnel who, in the course of their activities relating to their employment at Teknos (M) Sdn. Bhd. encounter actual or suspected violations of this policy are required to report their concerns using the available reporting channels. Reports made in good faith, either anonymously or otherwise, shall be addressed in a timely manner and without incurring fear of reprisal regardless of the outcome of any investigation.
8. Retaliation in any form against Personnel where the person has, in good faith, reported a violation or possible violation of this policy is strictly prohibited. Any Teknos Personnel found to have deliberately acted against the interests of any person who has in good faith reported a violation or possible violation of this policy shall be subjected to disciplinary proceedings including demotion, suspension, dismissal or other actions (including legal action) which Teknos (M) Sdn. Bhd. may pursue. The same policy applies to external parties who have reported a violation or possible violation of this policy. 

Audit and Compliance

Regular audits shall be conducted to ensure compliance to this policy. Such audits may be conducted internally by Teknos (M) Sdn. Bhd. or by an external party. Audit documentation should include performance improvement action plans. The results of audits shall be reported to the top management/business owner, directors and senior management as appropriate.

Sanctions for Non-Compliance

1. Non-compliance as identified by the audit and any risk areas identified through this and other means shall be reported to the top management and/or business owner in a timely manner in accordance with the level of risk identified.
2. Teknos (M) Sdn. Bhd. regards bribery and acts of corruption as serious matters and will apply penalties in the event of non-compliance to this policy. For Personnel, non-compliance may lead to disciplinary action, up to and including termination of employment.
3. For external parties, non-compliance may lead to penalties including termination of contract. Further legal action may also be taken in the event that Teknos (M) Sdn. Bhd.’s interests have been harmed by the results on non-compliance by individuals and organisations.

Monitoring and Continuous Improvement

1. Teknos (M) Sdn. Bhd. is committed to continuously improve the operations and effectiveness of its anti-bribery and anti-corruption initiatives.
2. Teknos (M) Sdn. Bhd. shall monitor its operating environment, identify changes in corruption risk, and seek opportunities for improving the anti-corruption initiatives.
3. The top management/business owner shall ensure regular assessments of the anti-corruption initiatives are carried out, to ensure its scope, policies, procedures and controls match the bribery and corruption related risks faced by Teknos (M) Sdn. Bhd.
4. Teknos (M) Sdn. Bhd. endeavours to impact the business environment where it operates. This includes supporting initiatives in the private and public sectors which are likely to improve the integrity of its operating environment. 

Published version: 1 March 2021