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Corporate Governance & Ethics

Anti-Bribery & Anti-Corruption (ABAC) Policy

VENOVOX SDN BHD (Co. Reg. No. 201101038146 (858858-M))

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Zero-Tolerance Commitment

Venovox adopts a zero-tolerance approach against all forms of bribery and corruption. We are committed to conducting business dealing with integrity, honesty, and respect, and in compliance with all applicable laws in all jurisdictions in which we operate.

1. Introduction

VENOVOX SDN BHD (Co. Reg. No. 201101038146 (858858-M)) (“Venovox”) is committed to conducting business dealings with integrity, honesty, respect and in compliance with all applicable laws and regulations in the countries where it does business. These laws include but are not limited to:

  • Malaysian Penal Code (revised 1977)
  • Malaysian Anti-Corruption Commission Act 2009 (revised 2018) (“MACCA”)
  • Malaysian Companies Act 2016
  • US Foreign Corrupt Practices Act 1977 (“FCPA”)
  • UK Bribery Act 2010
  • Australian Criminal Code Act 1995

These laws prohibit acts of bribery and corruption and mandate the establishment of adequate procedures by commercial organisations to prevent corrupt practices.

2. Scope & Applicability

This Policy applies to all individuals working at all levels and grades within Venovox, including directors, senior managers, employees (whether permanent, fixed-term, temporary, part-time or casual), consultants, contractors, trainees, seconded staff, homeworkers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person associated with Venovox, wherever located.

3. Key Definitions

Bribery & Corruption

Any action considered an offence of giving or receiving ‘gratification’ under the MACCA 2009. In practice, this means offering, giving, receiving or soliciting something of value in an attempt to illicitly influence decisions or actions.

Gratification

Money, donation, gift, loan, fee, reward, valuable security, property, financial benefit, employment, forbearance to demand money, or any service or favour of any description.

Conflict of Interest

Arises when a person's personal interests conflict with the responsibilities of their position or the interests of Venovox.

Facilitation Payments

Unofficial payments made to secure or expedite a routine governmental action or performance by a public official. Facilitation payments are strictly prohibited.

4. Policy & Procedures

4.1 General Principles

Venovox Personnel and Third Parties must not offer, promise, give, solicit or accept any bribe or gratification. Personnel must conduct due diligence, assess corruption risks, and immediately notify the Audit Committee if any conflict or irregular offer arises.

4.2 Gifts Policy

Venovox adopts a “No-Gifts Policy”, subject to very limited, bona fide business exceptions (such as corporate gifts bearing company branding, festival hampers shared among staff, or token souvenirs not exceeding nominal thresholds). Gifts must never be given or accepted during ongoing commercial tenders or contract negotiations.

4.3 Hospitality & Entertainment

Hospitality or entertainment given or received in the form of meals, cultural or sporting events must be legitimate, reasonable, and modest (under RM500 per event). Any travel arrangements for government officials, business partners, or customers must be pre-approved by Management in writing.

4.4 Sponsorships & Charitable Donations

All charitable donations and sponsorships must be legitimate, verified with due diligence by the Head of Internal Audit Committee, and receipted. Donations must never be used as a subterfuge for bribery.

4.5 Political Contributions

Venovox strictly prohibits making political contributions to political parties, candidates, or party officials under any circumstances.

4.6 Facilitation Payments

Employees and representatives must never pay, offer, or solicit facilitation or “grease” payments to expedite government or administrative processes.

4.7 Recruitment of Employees

Venovox conducts recruitment in a fair and transparent manner. Pre-employment background screening and fit-and-proper assessments are performed on candidates, particularly those appointed to sensitive or exposed positions.

4.8 Training & Communication

All personnel undergo mandatory regular training on anti-bribery, integrity, and ethical conduct. Completion records are maintained by Human Resources.

4.9 Business Partners & Due Diligence

Appropriate due diligence is conducted on all third parties before engagement. All business partners must execute the Third-Party Declaration Form (Appendix 2) confirming adherence to Venovox's anti-corruption standards.

5. Whistleblowing Channel

Confidential & Protected Reporting Mechanism

Venovox strongly encourages employees, business partners, customers, and any third party to report any suspected corruption, bribery, fraud, or unethical conduct. Complaints are treated with the strictest confidentiality and investigated by the Audit Committee. Informers and whistleblowers are protected pursuant to the law and company policy against any retaliation, harassment, or disadvantage.

By Email

Direct confidential inbox:

whistleblowing@venovox.com
By Phone

Dedicated reporting line:

03-7800 0088
By Mail

Audit Committee
Venovox Sdn. Bhd.
E-7-03, Block E Oasis Square,
No 2, Jalan PJU 1A/7, Ara Damansara,
47301 Petaling Jaya, Selangor.

Confidentiality Guarantee: Complaints shall only be known to persons assigned by the Audit Committee. Any unauthorised disclosure of whistleblower identity will result in severe disciplinary action, including summary dismissal.

6. Monitoring & Review

Venovox reviews this Policy on an annual basis to evaluate effectiveness and ensure continuous adequacy of our anti-corruption controls, reporting mechanisms, and training.

7. Sanctions for Non-Compliance

Non-compliance with this policy is treated as gross misconduct, leading to disciplinary action up to dismissal, contractual termination, and referral to regulatory and enforcement authorities (including the MACC).

Policy Appendices

The complete document includes formal declaration templates:

  • Appendix 1: Employee Anti-Bribery & Anti-Corruption Declaration Form
  • Appendix 2: Third-Party Anti-Bribery & Anti-Corruption Declaration Form