Anti-Bribery & Corruption Policy

CMC group of companies is committed to a zero-tolerance approach against any form of bribery and corruption. This policy serves as a guide to all employees, directors, partners, associates and third-parties on dealing with bribery and corrupt activities that may arise in the course of executing their professional duties, obligations and responsibilities.

CMC Group of Companies (collectively known as “CMC Group”) includes all companies listed in Appendix 1.

Third Party associates (collectively known as “Third-Parties”) is defined as any individual or organization with whom you may come into contact during the course of your work for CMC Group, and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisers, consultants and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

CMC Group does not tolerate any form of bribery and corruption. All employees and directors of CMC Group are placed in a position of trust and therefore, are expected to be honest and impartial when carrying out their duties to maintain the integrity of CMC Group.

1. Bribery and Corruption in this policy means any action which would be considered as an offence of giving or receiving cash, gifts or any under the Malaysian Anti-Corruption Commission Act 2009 (MACCA), which in practice means offering, giving, receiving or soliciting something of value with the intention to influence the decision or action of a person. It may either be:
1. Outbound: Where an employee or director acting on behalf of CMC Group has the intention to influence the action of a third-party for the benefit of CMC Group or
2. Inbound: Where a third-party has the intention to influence an employee or director with access to confidential information of any kind, to the advantage of the third-party.
2. Bribery and Corruption may take the form of anything of value, including money, goods, services, property, privilege, employment position or preferential treatment.

To ensure that third-parties share CMC Group’s standards of integrity, it is the responsibility of employees and directors to ensure the following:

1. For new third-party dealings, please undertake proper screening of third-party background and reputation
2. For existing third-party engagements, please ensure existing third-parties understand and sign the Third-Party Declaration Clause - refer to Appendix 2 (i)
3. For new and existing contracts, please ensure that the third-party declaration clause is included - refer to Appendix 2(ii)
4. All payments to and received from third-parties for business related matters must be supported by proper documents, payment trails and approvals.

CMC Group will continue to conduct proper background checks and ensure that potential employees have not been convicted in any corruption and / or bribery cases. New joiners shall also sign the Anti-Corruption Declaration for Employees. (Refer to Appendix 2)

1. All employees and directors are to read and understand this policy and sign the Anti-Corruption Declaration for Employees (refer to Appendix 3).
2. Employees and directors are required to re-certify their declaration on an annual basis by June every year.

All directors and employee are prohibited from receiving, seeking or soliciting gifts from third-parties with the intention of corruption and bribery. CMC Group prohibits the making and receiving of improper gifts, entertainment and travel which may influence business decisions. Directors and employees must comply at all times with all applicable laws and regulations related to the use of gifts, entertainment and travel in all countries in which CMC operate or have business dealings with.

1. CMC Group sales and front-line employees and directors may offer nominal gifts (eg: hampers) up to market value not exceeding RM500 per gift, AND, must be given in conjunction with public festival periods celebrated in the countries we operate in.
2. All gifts to third-parties must be approved by Head of Department and appropriately documented with receipts.
3. Any gifts to any government department for public festivals must have special approval from Head of Department and additional checks must be carried out to ensure that the relevant laws and policies applicable to the government official are complied with
4. When dealing with third-parties in foreign countries, Directors will exercise their best judgment and discretion.
5. No gifts of cash under any circumstances

1. CMC Group employees and directors may accept nominal gifts up to market value not exceeding RM500 per gift, AND, must be accepted in conjunction with public festival periods celebrated in countries we operate in.
2. All gifts must be disclosed to the Head of Department and shall be shared for the enjoyment and benefit of CMC Group employees’
3. Any gifts accepted above RM500 per gift must be disclosed and approved by Head of Department.
4. Gifts of cash (Ang Pau, gift vouchers, cards) must never be accepted
5. When dealing with third-parties in foreign countries, Directors will exercise their best judgment and discretion.

• Meals and drinks
• Tickets to sports, music or cultural events
• Travel and accommodation

• It is Infrequent
• It is non-solicited
• It is not given or accepted with the intention of corruption or bribery
• It Is not given as a preferential treatment
• It is moderate and appropriate in the context of the business occasion and your position in CMC Group

1. Facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. These tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
• Employees and directors are required to notify Head of Department and HR when they encounter such request for Facilitation payments.
2. A kickback is any payment, not reflected on the face of a business contract that is required to be made to a government agency, a government official or private individual in order to conclude a business agreement.
• Where a kickback is being extorted from an employee or director, the matter must immediately be reported to the Head of Department and HR.

1. Donations and sponsorships are permitted but CMC Group strictly prohibits the giving of donations or sponsorships which may influence business decisions or give rise to perceived business benefit for the CMC Group.
2. Directors and employees must ensure that all donations and sponsorships are made through legal and proper channels, with particular due diligence to ensure that sponsored charities and organization are licensed and legitimate.
3. All payments for the purpose of donations and sponsorships must be properly approved by the Directors and properly recorded.

1. CMC Group will ensure it keeps proper financial and non-financial records and has appropriate internal controls in place which will evidence any business reasons for all payments, allowable gifts and hospitality.
2. If you are aware of any cash payments, or payments made without a paper trail or without compliance with normal internal controls, please ensure that it is reported to Directors as this is not acceptable.

1. Any employee or director who breach this policy shall be subject to disciplinary proceedings, and expressly agrees that CMC reserves its right to terminate such employee and/or director’s employment with CMC Group in the event that such employee or director is found to have committed an act of breach in this policy.
2. Legal proceedings may be initiated against an employee or director in the event the CMC Group’s reputation have been affected as a result of such employee or director’s non-compliance with this policy.
3. Where reports are lodged against a director or employee who has been found to have committed an act of breach, CMC Group shall give its full cooperation to enforcement authorities to facilitate the investigations.
4. Non-compliance by third-parties will result in penalties, including termination of contracts, blacklisting, without prejudice to the right to initiate legal proceedings against them where CMC Group’s interest and reputation have been affected by the breach of policy by third parties.