a) An employee shall not be involved in any personal relationship with their immediate subordinates, as such relationships lead to favoritism and/or biased decisions, resulting in conflicts and undermining management activities.
b) An employee’s actions or approach shall not allow or promote a condition to develop into, or be deemed to be, sexual harassment in nature (refer to the 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 be subject to dismissal.
Allied Hori Sdn Bhd is highly committed to achieving and upholding high standards with regards to behaviour at the workplace. The Company is committed to conducting its business in accordance with the law and high ethical standards.
The policy aims to:
Whistle Blowing is a mechanism for employees to report or disclose, through an established medium, concerns about malpractices, unethical behaviour, illegal acts, or failure to comply with regulatory requirements that is taking place, has taken place, or may take place in future.
Under this Whistle Blowing policy, only 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 and malicious allegations shall be viewed as gross misconduct and, if proven, may lead to dismissal from work.
Any concerns shall be raised to the immediate superior. If for any reason this is not possible or appropriate, the concern shall be reported to the Managing Director (MD). The reporting mechanism is:
Allied Hori Sdn Bhd (Company No. 284253-K)
Name: Mr. Ian Leong
Telephone: 03-6091 5836 / 6091 4119 / 6091 2429
By mail, marked “Strictly Confidential”:
Allied Hori Sdn Bhd
Lot 8, Jalan Industri 3/2, Taman Industri Integrasi Rawang
48000 Rawang, Selangor Darul Ehsan
Attention: Managing Director
All reports will be investigated promptly by the receiving person. If required, they can seek assistance from other resources within the Company (e.g. the Human Resources Department). Reports received anonymously will be treated as confidential.
The person making an anonymous report will be advised that maintaining anonymity may hinder the investigation process. Anonymity will be maintained as long as it is permitted by law, or unless the person making the report indicates that they no longer wish to remain anonymous.
Once the investigation process is completed, an appropriate course of action will be recommended to top management for deliberation. Decisions taken by top management will be implemented immediately.
AHSB is committed to conducting its business in an ethical and lawful manner. The Anti-Bribery and Corruption (“ABC”) Policy enforces AHSB’s Professional Conduct, ensuring employees understand their responsibilities in complying with the Company’s zero tolerance for bribery and corruption. External providers are also expected to comply with this policy in relation to all work conducted with AHSB.
AHSB established its Anti-Bribery and Corruption Policy pursuant to the Malaysian Anti-Corruption Commission Act 2009 (revised 2018) and the Guidelines on Adequate Procedures pursuant to Subsection (5) of Section 17A under the MACC Act, as well as other legislation impacting the Company.
“AHSB” means Allied Hori Sdn Bhd.
“Bribery and Corruption” means any action which would be considered an offence of giving or receiving ‘gratification’ under the Malaysian Anti-Corruption Commission Act 2009 (MACCA) — in practice, offering, giving, receiving or soliciting something of value in an attempt to illicitly influence the decisions or actions of a person in a position of trust within an organization. Bribery may be ‘outbound’ (someone acting on behalf of AHSB to influence an external party, such as a government official or client decision-maker) or ‘inbound’ (an external party attempting to influence someone within the Company, such as a senior decision maker or someone with access to confidential information).
“Gratification” is defined in the MACCA to include: money, donations, gifts, loans, fees, rewards, valuable securities, property or any financial benefit or similar advantage; any office, dignity, employment or contract of employment or services; any payment, release, discharge or liquidation of any loan, obligation or other liability, in whole or in part; any valuable consideration, discount, commission, rebate, bonus or deduction; any forbearance to demand money or money’s worth owed; any other service or favour, including protection from any penalty, disability, or disciplinary, civil or criminal action; and any offer, undertaking or promise of the foregoing.
“Business Associates” means an external party with whom the Company has, or plans to establish, some form of business relationship — including customers, clients, outsourcing providers, contractors, sub-contractors, vendors, suppliers, consultants, advisers, agents, distributors, representatives, intermediaries, investors and service providers performing work for or on behalf of AHSB.
“Conflict of Interest” means when a person’s own interests 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 transparently and openly, normally bearing the Company’s name and logo — for example, diaries, table calendars, pens, notepads and plaques.
“Donation and Sponsorship” means charitable contributions and sponsorship payments made to support the community, for example sponsorship of educational events, or supporting NGOs and other social causes.
“Exposed Position” means a staff position identified as vulnerable to bribery through a risk assessment — including procurement or contract management, financial approvals, human resources and administration, relations with government officials or departments, sales, or other positions requiring negotiation with external parties.
“Corporate Hospitality” means corporate events or activities organized by external parties involving entertainment of personnel for the benefit of the organization, such as workshops, talks or seminars relevant to the business, industry or products.
“Personnel” means anyone employed by or working at AHSB, whether on a permanent, fixed-term or temporary basis, including interns and directors (executive and non-executive).
AHSB’s Human Resources Department is the owner of this policy.
AHSB is committed to adhering to anti-bribery and corruption laws, in particular the MACC Act, which imposes 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 they are a director, partner, employee, nominee, a person who manages the affairs of the company, an associated organization or corporation, a trustee, or any other person who performs services for or on behalf of the Company.
Under the Malaysian Anti-Corruption Commission Act 2009 (revised 2018), 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.
AHSB is committed to observing the following adequate procedures, based on the MACC’s T.R.U.S.T. principles:
Top-level management leads the Company’s efforts to improve the effectiveness of its corruption risk management framework, internal control system, periodic review and monitoring, and training and communication. The Managing Director (MD) and senior management are responsible for role-modelling a safe, transparent and trustful environment that promotes a culture of integrity, and the MD appoints suitable personnel to oversee the anti-corruption compliance programme.
The Company conducts bribery and corruption risk assessments at least annually, and whenever there is a significant change in the business or regulatory requirements, taking into account its relationships with third parties in its supply chain. The completed risk assessment is reviewed and signed off by the Company’s MD, together with the ABC Officer.
AHSB has put in place appropriate controls and contingency measures to address bribery and corruption risks, including:
Providing gifts. “Corporate gifts” usually bear the Company’s logo and name and are of nominal value, such as diaries, calendars, pens, notepads and plaques. “Festive or ceremonial gifts” are traditional treats or gifts customary to the occasion, such as mandarin oranges, hampers, mooncakes and dates. Corporate, festive or ceremonial gifts may be given to customers, business associates or other parties so long as: there is no expectation of favour or improper advantage from the receiver; there is no obligation to improperly or illegally influence any business decision; the gift is given for the right reason, as an act of appreciation or common courtesy; the value is reasonable and commensurate with the occasion — RM100.00 and below per item per person for a “Corporate Gift”, and RM500.00 and below per item per entity for a “Festive or Ceremonial Gift”; the gift is made openly and transparently; it complies with applicable laws; and any gift above the value limit is documented via the relevant form and approved by the Head of Department and Managing Director. Anti-Bribery and Corruption laws in Malaysia impose strict restrictions on the value of gifts to public officials.
Accepting gifts. Personnel and Business Associates are expected to communicate the ABC policy to external parties and decline gifts, except corporate gifts of nominal value or gifts handed over at conference speaking invitations (if in doubt, such gifts must be declined). Personnel and Business Associates must not directly or indirectly solicit gifts from any party, and must inform Human Resources and record any gifts received — irrespective of value — within three (3) working days of receipt. Cash or cash-equivalent gifts must never be accepted from any party with business dealings with AHSB.
Providing entertainment. AHSB recognizes the need to provide reasonable and proportionate entertainment, limited to RM100.00 and below (all inclusive) per person per occasion; any expense above this limit requires approval from the Head of Department and Managing Director. Personnel and Business Associates must exercise good judgement, must never provide entertainment in exchange for favours or advantages, and must never offer or promise entertainment to public officials.
Accepting entertainment. Personnel and Business Associates must decline entertainment and/or gratifications from external parties, must never accept them in exchange for exercising or not exercising their job function, and must inform Human Resources and record any entertainment or gratifications received within three (3) working days.
Providing corporate hospitality. Corporate hospitality through events such as sports or public events is a legitimate way to build business relationships, provided it is legal, made for the right reasons, reasonable in form and limit, and never provided or perceived as intended to obtain business or influence a decision. Special caution applies when hospitality involves public officials.
Accepting corporate hospitality. Personnel and Business Associates must not solicit or accept corporate hospitality that is illegal, inappropriate or excessive, or accept it in exchange for exercising or not exercising their job function, and must record any hospitality received with Human Resources within three (3) working days.
Donations and sponsorships that influence business decisions, including political contributions, are prohibited.
Facilitation payments — payments or other provisions made personally to an individual in control of a process or decision, intended to secure or expedite an administrative function — are prohibited. Any personnel who encounters a request for a facilitation payment must decline it and report it to management immediately. If a payment was made and its nature is uncertain, management must be notified immediately so it can be recorded accordingly.
The Company employs positions and awards contracts on a merit basis only; support letters are not recognized as part of the decision-making process.
Separation of duties and approving powers, or multiple signatories for transactions, are in place to ensure better risk control measures.
Any inadequacies in the anti-corruption monitoring framework are managed and improved through systematic review, monitoring and enforcement — the Company regularly reviews and assesses the performance, efficiency and effectiveness of the ABC framework through internal or external audit, monitors personnel compliance with ABC standards, and conducts disciplinary proceedings against non-compliant personnel where necessary. An awareness programme is conducted for all personnel on the Company’s position on anti-bribery and corruption, covering the policy, training, reporting channel and consequences of non-compliance. The ABC policy is made publicly available and communicated to all personnel and business associates.
Management shall review this Policy periodically, or at least once every three (3) years, and make any necessary amendments or improvements to ensure its continued effectiveness.
