Anti-Bribery and Corrupt Practices Policy

Definition Roles & Responsibilities Anti-Bribery and Corrupt Practices Standards Offences and Consequences Applicability Guiding Principles Risk Assessment and Controls Monitoring and Review Audit Training and Communication Reporting Of Bribery And Corrupt Practices Revision of Policy Record Keeping Management Reporting Exemption Whistleblower Protection And Investigation

Definition

For the purpose of this Policy:

Term	Definition
Board	The Board of Directors, including the Risk Management Committee of the Legal Entity Board/ Group Board, where the responsibilities of the Board have been delegated to such a Committee.
Senior Management	Group Chief Executive Officer (GCEO); Chief Executive Officers, Managing Directors – Line of Business, Group Chief Risk Officer, Group Chief Compliance Officer, Group Chief Human Resource Officer, Group Chief Financial Officer, Group Chief Operations Officer, Group Chief Internal Auditor and Group Company Secretary; Direct reports of (i) & (ii).
Head of Departments (HOD)	Head of a function or group functions within a Line of Business who reports to (i) and (ii).
Business Units (BUs)	Include Lines of Business (LOB) such as: Wholesale Banking Business Banking Retail Banking Islamic Banking Investment Banking Private Banking Funds Management Stockbroking Futures broking
Group Shared Services (GSS)	Include support and operations units within the Bank such as: Group CEO’s Office Group Corporate Communications & Marketing Group Company Secretarial Group Compliance Group Finance (including Capital & Balance Sheet Management, Group Corporate Services, Group Tax, Group Strategic Sourcing and Group Administration) Group Human Resource Group Information, Operations and Digital Banking Group Internal Audit Group Legal Group Risk Management (including Group Loan Rehabilitation) Group Strategic Transformation Officer Group Sustainability and any other department performing shared services/ support function that may be created in future.
Bribery and Corruption	Any action which would be considered as an offence of giving or receiving ‘gratification’ under the Malaysian Anti-Corruption Commission Act 2009 (MACC Act). 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 organisation. Bribery may be ‘outbound’ or ‘inbound’. Outbound is where someone acting on behalf of the Bank attempts to influence the actions of someone external, such as a government official or client decision-maker, whilst inbound is where an external party is attempting to influence someone within the Bank such as a senior decision-maker or someone with access to confidential information.
Gratification	Defined in the MACC Act to mean the following: 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; any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity; any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part; any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage; any forbearance to demand any money or money’s worth or valuable thing; 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 the forbearance from the exercise of any right or any official power or duty; and 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 Associate	Any external party with whom the Bank has, or plans to establish, some form of businesss relationship, these may include but not limited to: Vendors, suppliers, consultants, contractors, sub-contractors and service providers such as outsourcing providers. Distributors, agents, representatives, intermediaries, business partners and joint venture partners. Potential targeted mergers and acquisition target. Sponsorship partners, donation recipients and sustainability partners. Investors.
Conflict of Interest	A situation where an individual’s personal interest conflicts with the professional interest owed to the Bank and its customers.
Customer	Any person who uses, has used or may be intending to use, any financial service or product including: a representative of the customer (such as the parents of a minor and authorised representative); and a person who has entered or intends to enter into arrangement with the Bank (such as a guarantor or third party security provider) on account of or for the benefit of a customer;
Employees	All individuals directly contracted to the Bank on an employment basis, including permanent and temporary employees.
Government Officials	Includes, without limitation, candidates for public office, employees of government, national, municipal or local governments, state-owned enterprises and government linked companies.
Political Parties/Politician	Includes, without limitation, registered political parties, candidates for public office, officials of any political party.
Gift	covers anything of value, any bestowing of money, any item of value, service, loan/ financing, promise, advantage, benefit-in-kind, discount or rebate. “Gifts” can include the following (non-exhaustive list): Cash or cash equivalent Loans/Financing Souvenirs Gift cards or certificates Jewelleries Prizes Discounts Commissions/Fee Services Products Stocks/shares Hampers Travel and lodging Home improvements Movable/immovable properties Transportation Use of vehicle or vacation facilities Club memberships Tickets to entertainment/sport events Lottery tickets Favourable terms on a product or service Decorative items Flowers/chocolates