Anti-Bribery & Corruption Policy – Test

ANTI-BRIBERY & CORRUPTION POLICY

Introduction

Spatialworks Sdn Bhd (SPW) is committed to conducting all business of the Company in Halal, honest, ethical and professional manner wherever the company operates. This Anti-bribery and Corruption Policy (“Policy”) is made as a clear demonstration of that commitment. SPW adopts a zero-tolerance approach to corruption in any of its activities. This Anti-Bribery & Corruption (ABC) Policy is to further enhance the MNJ Group’s Business Ethics and Conduct as stipulated in the Employee Handbook to ensure that employees understand their responsibilities in compliance with the SPW’s zero tolerance for bribery and corruption.

This ABC Policy establishes basic standards and a framework for the prevention and detection of bribery and corruption in SPW’s operations. It promotes compliance with the Malaysian Anti-Corruption Commission Act 2009, and other applicable anti-corruption laws. The Malaysian Anti-Corruption Commission Act 2009 and many other anti-corruption laws prohibit offering or providing benefits, directly or indirectly, to government officials or to the private sector, for the purpose of securing an undue advantage or improper benefit.

Bribery and Implications

This ABC Policy shall apply to all directors and employees of SPW.​

Higher management personnel have additional responsibilities under the ABC Policy and are held to a higher standard of compliance. They are required to create and maintain an open environment that is comfortable for employees to ask questions, raise concerns and report misconduct.​

​

All directors and employees must refrain from any acts of bribery which takes the form of offering, promising, giving, demanding or receiving anything of value to anyone in the form of bribes, kickbacks and/or any other improper gratification (including gifts, loan, hospitality and entertainment) to improperly influence the outcome of any transaction, whether it is for their own personal benefit or for the benefit of SPW.​

​

SPW strictly does not tolerate any bribes given for purposes of obtaining or retaining business for SPW or provides an advantage to the businesses. SPW does not tolerate any such acts of bribery even in a personal capacity.​

​

​

Any directors and employees of SPW that breaches any of the ABC Policy may fall within the scope of serious misconduct and may be subjected to disciplinary action, up to and including dismissal, depending on the facts and circumstances of each case.

Definition

  • Gratification” shall have the meaning defined in the Malaysian Anti-Corruption Commission Act 2009 which includes but is not limited to anything of monetary and non-monetary value or benefit to the person. Gratification does not have to be directly given or received by an employee, but it can also be given or received by anyone related to the employee that is beneficial, of value or advantageous to the employee.
  • Gratification can be subdivided into the following categories (without limitation to):-