Corporate Governance

a) An employee shall not be involved in any personal relationship with their immediate subordinates as such relationship shall lead to favoritism and/or bias decisions, resulting in conflicts and under mining management activities.

b) An employee action or approach shall not allow or promote a condition to develop into or deem to be sexual harassment in nature (refer to Sexual Harassment Policy).

c) A married employee shall not enter into an extramarital affair with any Company staff.

d) Any employee found to have committed such an act shall subject to dismissal.

9.6.10.1 Policy Statement 

Allied Hori Sdn Bhd is highly committed in achieving and upholding high standards with regards to behaviour at workplace. The Company is committed in conducting its business in accordance with the law and high ethical standards. 

The policy aims to:

1. provide possibility for employees and all stakeholders (i.e. customers / suppliers) to report serious concerns about malpractices, unethical behaviour, illegal acts or failure to comply to the regulatory requirements without fear;  
2. ensure that such concerns are dealt appropriately; 
3. reassure that any person raising any serious concern in good faith and would be protected from reprisals

9.6.10.2 Whistle Blowing

Whistle Blowing is a mechanism for employees who have concerned could report or disclose through established medium if his concern about malpractices, unethical behaviour, illegal acts, failure to comply with regulatory requirements that is taking place/taken place and may take place in future. 

Under this Whistle Blowing policy, only the genuine concerns shall be reported. The report should be made in good faith with a reasonable belief that the information and any allegation(s) are genuine and not for personal gain. False allegations and malicious shall be viewed as gross misconduct and if proven may lead to dismissal from work. 

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9.6.10.3 Procedures

Any concerns shall be raised to the immediate superior. If for any reason, it is believed that this is not possible or appropriate, then the concern shall be reported to the Managing Director (MD). The reporting mechanism are:  

Allied Hori Sdn Bhd (Company No. 284253-K)
Name: Mr. Ian Leong 
Email: [email protected]
Telephone: 03-6091 5836 / 6091 4119 / 6091 2429

By mail: Mark “Strictly Confidential”

Allied Hori Sdn Bhd
Lot 8, Jalan Industri 3/2
Taman Industri Integrasi Rawang 48000 Rawang Selangor Darul Ehsan

Attention to: Managing Director

9.6.10.4 Action

All reports will be investigated promptly by the receiving person. If required, he can seek assistance from other resources within the Company (e.g. Human Resources Department). 

Reports received anonymously will be treated as confidential. 

The person making anonymous report would be advised that maintaining anonymity may hinder investigation process. Anonymity will be maintained as log as it is permitted by law or the person making the report indicates that he no longer wishes to remain anonymous. 

Once the investigation process is completed, appropriate course of action will be recommended to the top management for deliberation. Decision taken by the top management will be implemented immediately.

AHSB is committed to conduct its business in an ethical and lawful manner. In line with that, the Anti-Bribery and Corruption (“ABC”) Policy is to enforce AHSB’s Professional Conduct to ensure that employees understand their responsibilities in compliance with the Company’s zero tolerance to bribery and corruption.   The external providers are also expected to comply with this policy in relation to all works conducted with AHSB.  

AHSB established Anti-Bribery and Corruption Policy in pursuant to the Malaysian Anti-Corruption Commission Act 2009 (revised 2018) and Guidelines on Adequate Procedures pursuant to Subsection (5) of Section 17A under the MACC Act (Guidelines on Adequate Procedures) as well as legislations impacting the Company. 

9.6.11.1 References

Human Resources Policy Manual

Section 17A of Malaysian Anti-Corruption Commission Act 2009

Professional Conduct Whistle Blowing Policy

9.6.11.2 Definitions

“AHSB” means Allied Hori Sdn Bhd;

“Bribery and Corruption” means any action which would be considered as an offence of giving or receiving ‘gratification’ under the Malaysian Anti-Corruption Commission Act 2009 (MACCA). In practice, this means offering, giving, receiving or soliciting something of value in an attempt to illicitly influence the decisions or actions of a person who is in a position of trust within an organization

Bribery may be ‘outbound’, where someone acting on behalf of AHSB to influence the actions of someone external, such as a Government official or client decision-maker. It may also be ‘inbound’, where an external party is attempting to influence someone within the Company such as a senior decision maker or someone with access to confidential information.

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“Gratification” is defined in the MACCA as following: –

(a) money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit or any other similar advantage;

(b) any office, dignity, employment, contract of employment or services and agreement to give employment or render services in any capacity;

(c) any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;

(d) any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;

(e) any forbearance to demand any money or money’s worth or valuable thing;

(f) any other service or favour of any description including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted and including the exercise or forbearance from the exercise of any right or any official power or duty and

(g) any offer, undertaking or promise whether conditional or unconditional of any gratification within the meaning of any of the preceding paragraphs (a) to

(f) “Business Associates” means an external party with whom the Company has, or plans to establish some form of business relationship. This may include customers, clients, outsourcing providers, contractors, sub-contractors, vendors, suppliers, consultants, advisers, agents, distributors, representatives, intermediaries, investors and service providers of any kind performing work and services, for and on behalf of AHSB. 

“Conflict of Interest” means when a person’s own interests either influence have the potential to influence or are perceived to influence their decision making in the Company.

“Corporate Gift” means something given from one organization to another with the appointed representatives of each organization giving and accepting the gift. Corporate gifts may also be promotional items given out equally to the general public at events, trade shows and exhibitions as a part of building the Company’s brand. The gifts are given transparently and openly with the implicit or explicit approval of all parties involved. Corporate gifts normally bear the Company name and logo. Examples of corporate gifts include items such as diaries, table calendars, pens, notepads and plaques.

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“Donation and Sponsorship” means charitable contributions and sponsorship payments made to support the community. For example, sponsorship of educational events, supporting NGOs and other social causes.

“Exposed Position” means a staff position identified as vulnerable to bribery through a risk assessment. Such positions may include any role involving: procurement or contract management, financial approvals, human resources and administration, relations with government officials or government departments, sales, positions where negotiation with external party is required or other positions which the Company has identified as vulnerable to bribery. 

“Corporate Hospitality” means corporate events or activities organized by external parties which involves entertainment of personnel and/or other parties for the benefit of the organization such as workshops/talks/seminars relevant to business/industry/products. External parties refers to suppliers, vendors, contractors, sub-contractors, consultants, customers, service providers or stakeholders with whom business relationship is in existence (past, present or potential);

“Personnel” means anyone who is employed by or works at AHSB whether permanent, fixed-term or temporary basis, interns and directors (executive and non-executive).  

9.6.11.3 Policy Owner

AHSB’s Human Resources Department is the owner of this policy. 

9.6.11.4 Offences of Bribery and Corruption

AHSB is committed to the adhering anti-bribery and corruption laws, in particular the MACC Act which imposes the corporate liability. A company commits an offence when a person associated with the Company commits bribery and corruption. A person is associated with the Company if he/she is a director, partner, employee, nominee, a person manages the affairs of the company, associated organisation and corporation, trustee and any other person who performs services for or on behalf of the Company. 

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Under the Malaysian Anti-Corruption Commission Act 2009 (revised 2018) (MACC Act), bribery and corruption are criminal offences and the legal consequences include a fine of up to 10 times the amount of the Gratification subject to a minimum of RM1 million and/or imprisonment of up to twenty (20) years. A commercial organization commits an offence if an associated person corruptly gives any gratification with intent to obtain or retain business or an advantage in the conduct of business, for the commercial organization.

9.6.11.5 Anti-Bribery Policy & Corruption (“ABC”) Standards

AHSB is committed to observe the following adequate procedures based on the MACC’s T.R.U.S.T. principles:

1. Top Level Commitment

The top-level management leads the Company’s efforts to improve upon the effectiveness of its corruption risks management framework, internal control system, periodical review and monitoring and training and communication. The Company’s Managing Director (MD) and senior management have the responsibility to be role models in building a safe, transparent and trustful environment in promoting a culture of integrity within the organization. The MD will appoint suitable personnel tasked with the responsibility for overseeing the anti-corruption compliance and programme are appropriate.

2. Risk Assessment

The Company conducts bribery and corruption risk assessments at least annually and when there is any significant change in the business or regulatory requirements. When performing risk assessments, the Company takes into consideration of various factors including its relationship with third parties in its supply chain.

The completed risk assessment is reviewed and signed-off by the Company’s MD as the person accountable for the ABC Policy together with the ABC Officer. 

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3. Undertake Control Measures

AHSB has put in place the appropriate controls and contingency measures to address any bribery and corruption risks as following:

3.1 Due diligence

The Company conducts due diligence on any relevant parties or personnel prior to entering any formalised relationships. Methods may include background checks, document verification process and risk assessment.

3.2 Reporting Channel

The Company has accessible and confidential reporting channel through its Whistle Blowing Policy. The Company encourages internal and external parties to raise concerns of bribery and corruption and their identities would be protected. AHSB prohibits retaliation against those making reports in good faith.

3.3 “ABC” Policy

The Company’s policy must be approved by the top management and is reviewed and/or refreshed annually and when there is any significant change I the Company’s business and regulatory requirements in order to ensure the Company’s ABC Policy remains up-to-date and relevant. 

3.4 A general Anti-Bribery Corruption (“ABC”) Statement

AHSB ensures clear and firm stand to all employees and stakeholders that bribery and corruption are unacceptable.

3.5 Conflict of Interest 

AHSB requires declaration of conflict interest to manage such risks as stated in the Employee Handbook. 

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3.6 Gifts, Entertainment and Hospitality

3.6.1 Providing Gifts 

1. “Corporate gifts” usually bear Company’s logo and name and are of nominal value such diaries, calendars, pens, notepads and plaques. 

1. “Festive or ceremonial gifts” are traditional treats or gifts customary to the occasion i.e. mandarin oranges, hampers, mooncakes, dates and etc. 

1. Corporate gifts, Festive or Ceremonial gifts may be given to customers, business associates, or other parties so long it meets the following conditions: –

(i) no expectation – there must not be any expectation, favour or improper advantages from the receiver;

(ii) no obligation – not to be used to induce the receiver to improperly or illegally influence any business decision;

(iii) made for the right reason – should be given as an act of appreciation or common courtesy during festive seasons or ceremonial occasions; 

(iv) reasonable value – the value must commensurate with the occasion and in accordance with general business practices. The value for “Corporate Gift” must be RM100.00 and below per item per person whereas the value for “Festive Gift or Ceremonial Gift” must be RM500.00 and below per item per entity;

(v) made openly – no concealment and to be done in transparent manner;

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(vi) to be legal – it complies with applicable laws;

(vii) to be documented – any gifts that are above the value limit set is required to complete and submit the relevant form to the Head of Department and Managing Director for approval (please refer to Appendix 1). 

1. Anti-Bribery and Corruption Laws in Malaysia impose strict restrictions on the value of gifts to public officials. 

3.6.2 Accepting Gifts 

1. Personnel and Business Associates are expected to communicate the “ABC” policy to external parties and to decline gifts. However, the following are the exceptions: –

(i) corporate gifts of nominal value;

(ii) gifts handed over during invitations to speak at conferences. If in doubt, such gifts must be declined. 

1. Personnel and Business Associates must not directly or indirectly solicit for gifts from any party, family or/and for on behalf of AHSB.  

1. Personnel and Business Associates must inform Human Resources Department and  record any gifts received, irrespective of value using the appropriate form (please refer to Appendix 4) within 3 (three) working days of receipt of any gifts. Personnel (or anyone on their behalf) must not accept gifts in the form of cash or cash equivalent from any party having business dealings with AHSB. 

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3.6.3 Providing Entertainment 

100. Within the business environment, it is common practice to provide entertainment to create and maintain business relationships. Therefore, AHSB recognizes the need to provide reasonable and proportionate entertainment limit of RM100.00 and below (all inclusive) per person per occasion.  

1. Any entertainment expenses above the limit stated above requires completion and submission of relevant form to the Head of Department and Managing Director for approval (please refer to Appendix 3).

1. Personnel and Business Associates are expected to exercise good judgement and care when providing entertainment to external parties. 

1. Personnel and Business Associates must not directly or indirectly provide or offer to provide entertainment in exchange for favours or advantages which will be considered as corruption.
2. Anti-Bribery and Anti-Corruption laws in Malaysia impose strict restrictions on the level of entertainment and value to be accorded to the public officials. Therefore, AHSB is committed to comply to all applicable laws in Malaysia. Personnel and Business Associates must not offer or promise to provide any entertainment to public officials. 

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3.6.4 Accepting Entertainment 

1. Personnel and Business Associates are

expected to communicate the “ABC” policy to external parties and to decline entertainment and/or gratifications from external parties including customers.  

1. Personnel and Business Associates must not accept entertainment and/or gratifications from any party and conduct with integrity at all time. Personnel or any family members must not accept entertainment and/or gratifications in exchange for exercising and or non- exercising of their job function or activities.

1. Personnel and Business Associates must inform Human Resources Department and  record any entertainment and/or gratifications received by using the appropriate form (please refer to Appendix 4) within 3 (three) working days of receipt of any entertainment and/or gratifications from any third party having business dealings with AHSB.

3.6.5 Providing Corporate Hospitality 

1. Providing corporate hospitality through corporate events such as sports or public events, is a legitimate means to build business relationships, business network and promote goodwill.  

1. Personnel and Business Associates must communicate AHSB’s “ABC” policy to external parties to exercise good judgement and care that such arrangement is legal under the applicable laws, made for the right reasons and at the same time reasonable in its form and limit.  
2. More importantly, it must not be provided or it projects perception that it is accepted in order to obtain business or giving advantage of any kind or influence of a business decision making.

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1. Anti-Bribery and Anti-Corruption laws in Malaysia impose strict restrictions on the level of entertainment and value to be accorded to the public officials. Therefore, AHSB is committed to comply to all applicable laws in Malaysia. Personnel and Business Associates must be exercising special caution or when providing corporate hospitality to public officials.

3.6.6 Accepting Corporate Hospitality 

1. Personnel and Business Associates must not directly or indirectly solicit for corporate hospitality or accept corporate hospitality of any form that are illegal, inappropriate or excessive in anticipation to influence for a favorable business decision making.

1. Personnel and Business Associates must not accept corporate hospitality from any party and conduct with integrity at all time. 

Personnel or any family members must not accept corporate hospitality in exchange for  exercising and or non-exercising of their job function or activities.

1. Personnel and Business Associates must inform Human Resources Department and record any entertainment and/or gratifications received by using the appropriate form (please refer to Appendix 4) within 3 (three)  working days of receipt of any entertainment  and/or gratifications from any party having  business dealings with AHSB.

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1. More importantly, it must not be accepted or projects perception that it is accepted in order to obtain business or giving advantage of any kind or influence of a business decision making.

3.7 Donations and Sponsorships

Donations and sponsorships influencing business decisions are prohibited including political contributions. 

3.8 Facilitation Payments

Facilitation payments are prohibited by the Company. Facilitation payments defined as a payment or other provision made personally to an individual in control of a process or decision making. The payment is intended to secure or expedite the process of administrative function.

Any personnel encounters request for facilitation payment shall decline the payment and report to the management immediately. If payment was made and the personnel is not certain of the nature, the management must be notified immediately so that the payment could be recorded accordingly.   

3.9 Support Letters 

The Company employ positions and award contracts on merit basis only. As such, support letters shall not be recognized as part of the decision-making process. 

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3.10 Financial and Non-Financial Controls

Separation of duties and approving powers or multiple signatories for transactions shall be in place in order to ensure better risk control measures. 

3.11 Monitoring Framework

Any inadequacies in the anti-corruption monitoring framework shall be managed and improved.

4. Systematic Review, Monitoring and Enforcement

The Company regularly review and assess the performance, efficiency and effectiveness of the ABC framework through internal audit or external audit, monitor the performance of personnel in relation to the ABC standards and conduct any disciplinary proceedings against personnel found to be non-compliant to the programme.  

5. Training and Communication

The Company shall conduct an awareness programme for all its personnel on the Company’s position regarding anti-bribery and corruption especially in relation to their role within or/and outside the Company covering the policy, training, reporting channel and consequences for non-compliance. 

The ABC policy should be made publicly available and appropriately communicated to all personnel and business associates.

9.6.11.5 Review of the Policy

The Management shall review the Policy periodically or at least once every three (3) years and to make any necessary amendments/improvements when deemed necessary to ensure the effectiveness of the policy.