Anti-Bribery and Corruption Policy

1.0 PURPOSE
The purpose of the Anti-Bribery and Corruption Policy (hereinafter referred to as “ABCP”) is to establish adequate procedures to prevent, detect and mitigate the risk of any conduct of bribery or corruption amongst the employees. This Policy shall address the consequences of non-compliance, and aim to deter unprincipled conduct amongst our employees and third parties.

The ABCP is developed to:
  • Set out the responsibilities of ViTrox and employees of ViTrox, in observing and upholding ViTrox's position against the act of bribery and corruption; and
  • Furnish information and guidance on how to recognise and deal with bribery and corruption issues.
2.0 SCOPE
The scope of this ABCP applies to ViTrox and all of its subsidiaries. It applies to the Board, the employees (whether on a permanent, contractual or temporary basis) and third parties acting on behalf of ViTrox.

Third parties refer to business associates who have dealings with ViTrox such as, sub-contractors, vendors, consultants, agents, representatives, distributors, sales channel partners, public bodies, customers and other intermediaries who perform work or services for/on behalf of ViTrox.
3.0 STATEMENT
3.1 INTRODUCTION
In ViTrox’s commitment in upholding a zero-tolerance approach on bribery and corruption practices, an ABCP has been developed in cohesion with our Anti-Bribery Management System (“ABMS”) to distinguish the boundaries of interactions and dealings between all employees of ViTrox and external parties. Parallel with fulfilling their legal obligations, ViTrox firmly believes that the foundation in maintaining sustainable business relationships rests upon honesty, integrity and ethical business practices.

This ABCP governs the measures to be taken when an employee or third parties are subjected to any potential acts of bribery or misconduct that could curtail the efforts of ViTrox in combating act of bribery and corruption. As such, the ABCP is to be read in conjunction with ViTrox’s Code of Ethics, and the Malaysian Anti-Corruption Commission Amendment Act (2018) (“MACCA”).
3.2 ANTI-BRIBERY AND CORRUPTION COMMITMENT
The Board of Directors (“Board”) of ViTrox and Top Management are committed in executing their corresponding business functions or performance in a fair and transparent manner in order to prevent, detect and mitigate the risks of unethical practices.

The FIVE (5) fundamental principles, (i.e. Integrity, Accountability, Courage, Trust and Respect and Gratitude and Care) cultivated throughout ViTrox demonstrates the commitment of the Board and Top Management of ViTrox in advocating for a robust working culture in ViTrox.

In addition to the 5 fundamental principles, the key etiquettes of No Bribe/Cheat, No Blame, No Give Up, No Criticise/Condemn and No Complacent (B.B.G.C.C.) are to be duly observed by all levels of employees without exception.

The Top Management shall routinely monitor the bribery and corruption risks of ViTrox and report all prominent cases to the Board for expedited resolution.
3.3 GIFTS, ENTERTAINMENT AND CORPORATE HOSPITALITY
3.3.1 Gifts
ViTrox expresses its stance of not accepting or receiving any gift in its Gift, Meals, Entertainment, and Travel Policy (“GMET Policy”). The Board and the employees, immediate family members, or relatives and all persons with close relationship acting on behalf of ViTrox are strictly prohibited from directly, or indirectly to solicit or receive gifts to gain unfair business advantage or benefit to a personal, immediate family and agent which would be perceived to contain bribery and corruption elements.

Under no circumstances shall the Board and the employee, his/her immediate family members or relatives and all persons with close relationship accept gifts in the form of cash or cash equivalents.
3.3.2 Corporate Hospitality (Meals and Entertainment)
Corporate hospitality which includes meals and entertainment must be unsolicited and thus does not affect, or to be perceived to contain bribery or corruption elements.

Meals and entertainment shall only be offered to, or received from the representative dealings with external parties or service providers in their role in ViTrox in conjunction with legitimate business dealings or business meetings, and shall not be as a stand-alone basis.
3.4 DEALINGS WITH PUBLIC OFFICIALS
ViTrox prohibits any kind of donation or in-kind political contribution to any political parties, organisations associated with public officials, political party officials or candidates for political office.

The Board and the employees are encouraged to exercise vigilance in their interactions with public officials.
3.5 FACILITATION PAYMENTS
ViTrox prohibits giving or accepting any facilitation payment by external parties or public officials. The Board and the employees shall disclose incidents that involve facilitation payments to the Head of Department and Anti-Bribery Compliance Team (“ABCT”) as soon as possible.

ViTrox only permits individuals from public officials or private entities to request for payment in exchange for facilitating administrative services such as customs declaration, port clearance, issuance of travelling visa, passport clearance at frontiers, loading and unloading of cargo and processing of working permits.
3.6 CORPORATE SOCIAL RESPONSIBLITIES (“CSR”), SPONSORSHIPS AND DONATIONS
All CSR activities, sponsorships and donations made must be in good faith without the intention to bribe, have any corrupt intent or any means to cover up an undue payment or bribery.

ViTrox prohibits the giving or receiving of sponsorships and donations which may influence a business decision.

The Board and the employees are required to maintain good judgement in assessing the recipient or organisation.
3.7 DEALINGS WITH THIRD PARTIES
ViTrox networks with a range of third parties that includes but not limited to sub-contractors, vendors, consultants, agents, representatives, distributors, sales channel partners, public bodies, customers and other intermediaries in which ViTrox has strongly emphasised that all business dealings with third parties must be carried out in compliance with all relevant laws, and consistent with the values and principles of ViTrox’s Code of Ethics.

ViTrox does not tolerate any form of bribery and corruption and shall only conduct business dealings with third parties who pledge to ViTrox’s stance.
3.8 SANCTIONS ON NON-COMPLIANCE
As part of ViTrox’s efforts to mitigate the bribery and corruptions risks, the Board has established the ABCT to provide the necessary guidance and supervision pertaining to the bribery and corruption incidents (if any) as raised by the third parties of ViTrox. Upon verification, appropriate disciplinary and remedial actions will be deliberated and taken against the breaching party.

Any suspicion or evidence of any employees or anyone acting for or on behalf of ViTrox engaging in bribery and corruption must be reported at the earliest opportunity to immediate supervisors or through vitroxwhistle@gmail.com. All reports shall be taken seriously and ViTrox shall safeguard those third parties or employees who have made the allegation in good faith.
3.9 FOREWARNINGS
If the Board, Management or employee encounters any of the following warning signs, he/she shall apprise the ABCT expeditiously.

The following illustrates a non-exhaustive list of forewarnings that may prompt the Board and the employees of any potential concerns with the third parties.
  • Objections to anti-bribery warranties in the agreements/contract;
  • Attempts to offer lavish or excessive entertainment by a third party;
  • Reputed affiliation in improper business conducts or well known for soliciting or providing bribes;
  • Transaction involves a country known for high incidence of corrupt payments;
  • Family, business or other “special” ties with government or public officials;
  • Convoluted payment arrangements such as payment in cash payment to third party or request for advances for expenses other than fees;
  • Requests for anonymity;
  • Absence of established workplace or inadequate credentials for the nature of engagement;
  • Frequent submission of inconsistent data without valid justification;
  • Reference checking reveals dubious background or reputation of the third party; and
  • Abrupt change in lifestyle, for e.g. lavish lifestyle, extravagant purchases.
3.10 REFERENCES
  • Section 17A of the Malaysia Anti-Corruption Commission Act, 2009 (“MACC Act”)
  • Malaysian Anti-Corruption Commission Amendment Act (2018) (“MACCA”)
  • ViTrox Employee Handbook
  • Whistleblowing Policy
  • ViTrox’s Code of Ethics
  • ViTrox’s Business Integrity Undertaking Letter
  • Gifts, Entertainment and Corporate Hospitality Policy
  • Facilitation Payments Policy
  • Political Contributions Policy
  • Dealing with Third Parties and Public Officials Policy