About Us

1. Introduction

Adipven (M) Sdn. Bhd. (“Adipven”) is implementing Anti-Bribery and Anti-Corruption Policy (“the Policy”). The Policy elaborates on principles of bribery and other corrupt practices that may arise in the course of business.

The Policy is not intended to be the one-stop center for all definitive answers. Rather, it is intended as an introduction to our Employees, as well to the public at large, of Adipven’s commitments to combat bribery and corruption. This is the cornerstone of further initiatives towards greater governance, including periodic assessment of potential risk areas in our business that may be exposed to corrupt practices, as well as sanctioned budget and strategies to uphold and strengthen Adipven.

Bribery entails severe consequences for everyone. Dismissal, fines, and imprisonment, not to mention financial and reputational damages, are negative consequences that may confront.

Each Employee of Adipven shall uphold high levels of personal and professional values in all business interactions and decisions. The nature of Adipven’s business requires its employees to engage in business with a wide range of parties, both internal as well as external. The Policy establishes the boundaries on interactions with all parties. The Policy also provides guidance on how to act when subjected to potential acts of bribery and matters of corruption. The Policy shall be read with the Whistleblowing and the Malaysian Anti-Corruption Commission Act 2009 and its 2018 amendment (“MACCA”).

2. Objectives

The Policy sets out Adipven’s position on bribery in all its forms and matters of corruption that might confront Adipven in its day to day operations.

3. Scope

The Policy applies to all Directors and Employees of Adipven.

4. Adipven’s Commitments

Adipven is committed to conducting business dealings with integrity. This means avoiding practices of bribery and corruption of all forms in Adipven’s daily operations. Adipven has adopted a zero tolerance approach against all forms of bribery and corruption and takes a strong stance against such acts. The scenarios provided within the Policy do not limit the boundaries of the Policy which may be extended to cover all circumstances relating to bribery. Compliance to the Policy is mandatory and will be monitored with a principle-based approach.

5. Definitions

The following definitions are included in the Policy.

6. The Policy

All forms of bribery and corruption are prohibited. Adipven upholds a zero tolerance approach. In addition to bribery, Employees must not participate in any corrupt activity, such as extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering.

Bribery may take the form exchange of money, goods, services, property, privilege, employment position or preferential treatment. Employees shall not therefore, whether directly or indirectly, offer, give, receive or solicit any item of value, in the attempt to illicitly influence the decisions or actions of a person in a position of trust within Adipven, either for the intended benefit Adipven or the persons involved in the transaction.

The Policy applies equally to its business dealings with any entities, and includes interactions with their directors, Employees, agents and other appointed representatives at all levels. Even the perception of bribery is to be avoided.

The Policy applies to all countries worldwide, without exception and without regard to regional customs, local practices or competitive conditions.

No Employee will suffer demotion, penalty or other adverse consequences for refusing to pay or receive bribes or other illicit behaviour, even if such refusal may result in Adipven losing business or experiencing a delay in business operations.

Adipven recognises the value of integrity in its Employees and Directors. Adipven’s recruitment, training, performance evaluation, remuneration, recognition and promotion for all Employees, shall be designed to recognise integrity. Adipven conducts due diligence on employees who holds or may be holding, Exposed Positions.

Adipven does not offer employment to prospective Employees in return for previous favour/in exchange of improper favour.

Adipven awards contracts and employee positions purely based on merits. Support letters in all forms shall not be recognised as part of the business decision making process.

7. Recognition of local and international legislation

Adipven is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including but not limited to MACCA, Malaysian Penal Code (revised 1977) (and its amendments), the Companies Act 2016 (Malaysia), the US Foreign Corrupt Practices Act 1977 (amended 1998), and the UK Bribery Act 2010. These laws prohibit bribery and corruption. Organisations are mandated to establish and maintain accurate books and records as well as adequate measures to prevent corrupt practices.

In cases of conflict between mandatory law and the principles contained in the Policy, the law shall prevail.

8. Gifts, Entertainment and Travel and Donation and Sponsorship

Adipven prohibits both the giving and receiving of Gifts, Entertainment and Travel (GET) and Donation and Sponsorship (D&S) to influence business decisions. Employees must comply with all applicable policies, procedures, laws and regulations related to the use of GET in all countries in which Adipven is operating or may operate in the future.

It is acknowledged that the practice of business gifts and donation varies between countries, and what may be deemed as acceptable in one country may not be in another. Divisions and/or Regions are therefore encouraged to develop further guidelines cascading from this Policy, to streamline thresholds and develop specific requirements applicable to the respective Division/Region.

Adipven allows appropriate business-related GET. Reasonable GET are acceptable provided that an Employee should be comfortable to disclose to her/his colleagues the GET and D&S that you offered/received, an Employee only offer/accept GET and D&S to/from those who will not put you in a position of conflict, the GET and D&S must not be offered/accepted when there is a pending business decision, the GET and D&S must be modest and must not be so frequent as to place the recipient under an obligation and the intention behind the GET and D&S must not be interpreted as to gain unmerited advantage.

Where possible, Employees should avoid from offering and/or accepting GET and D&S to/from government officials. If a gift is deemed appropriate, a Corporate Gift for a specific purpose is encouraged as opposed to a Personal Gift. GET must be reasonable and proportionate to the income of the Government official such that the no obligation is created by the provision of the hospitality resulting in a decision to the advantage of the business. All offers and acceptance of GET and D&S involving government officials must be approved by the Managing Director and the Directors. The GET and D&S must also be declared to the Managing Director and the Directors.

In respect of political contributions, funds or resources of Adipven must not be used to make any direct or indirect political contributions on behalf of Adipven. Any appearance of making such contributions or expenditure to any political party, candidate or campaign, must also be avoided.

Donations in the form of charity may be permissible depending on the circumstance but should be made directly to an official entity and be able to be disclosed publicly when required to.

Discounts, provisions of free products and services, provision of vehicles at discounted or zero cost rates, servicing and other provisions are not permitted in exchange for undue influence.

9. Facilitation payments

Adipven adopts a strict stance that disallows facilitation payments.

Employees are expected to notify their immediate superior when encountered with any requests for a facilitation payment. In addition, if a payment has been made and Employees are unsure of the nature, their immediate superior must be immediately notified and consulted. They must also ensure that the payment has been recorded transparently.

Adipven equally uphold the safety of all Employees as priority. In the event that an Employee’s safety is at stake, a facilitation payment to protect the Employee is permitted if that is the immediate available recourse to protect the safety of the Employee, or the Managing Director and the Directors’ approval has been obtained, or payment under the state of emergency had been undertaken, after which the Managing Director or Directors’ approval must be retrospectively obtained as soon as possible.

10. External parties

As part of Adipven’s commitment to combat bribery, Adipven expects all External parties to refrain from bribery. If suspicion of bribery and corruption arises in the dealings with any External party, Adipven shall seek an alternative provider of the services / goods.

Adipven expects all External parties acting on behalf Adipven to contractually agree to refrain from bribery and corruption, and to adhere to the Policy.

If Adipven is not satisfied that bribery and corruption prevention has been upheld, due diligence shall be undertaken with regards to any External party intending to act on the Adipven’s behalf. The extent of the due diligence should be risk-based and shall include a bribery risk assessment. Due diligence may include a search through relevant databases, checking for relationships with public officials, and documenting the reasons for choosing one particular External parties over another.

Adipven shall endeavour to include clauses in all contracts enabling Adipven to terminate any contract in which bribery or corruption has been observed.

Guidance and standards for appropriate practices and behaviours are expected to also be regulated to prevent corrupt practices.

Where the requirements may not be immediately apparent, the Managing Director and Directors shall be consulted.

11. Responsibilities of Employees

Employees are responsible for understanding and complying with The Policy. In particular, the role of all Employees includes be familiar with applicable requirements and directives of the policy and communicate them to subordinates, promptly record all transactions and payments accurately and in reasonable detail, always raise suspicious transactions to immediate superiors for guidance on next course of action, promptly report violations or suspected violations through appropriate channels and promptly complete COBC trainings and assessments, as well as attest to comply annually.

12. Conflict of interest

Conflicts of interest arise in situations where there is a personal interest that might be considered to interfere with that person’s objectivity when performing duties or exercising judgement on behalf of Adipven. Employees should avoid or deal appropriately with situations in which personal interest could conflict obligations or duties. Employees must not use their position, official working hours, Adipven resources and assets for personal gain or to Adipven’s disadvantage.

The Policy sets out the procedures on how to deal with conflicts of interests arising with a selected Adipven of individuals and entities, including dealing with suppliers, clients, agents and competitors, personal dealings with suppliers and clients, activities outside Adipven and family members and close personal relationships.

In situations where confronted with such conflict, Employees are required to notify the Managing Director and the Directors.

13. Staff declarations

All Employees are expected to follow and comply with the Policy in the course of his/her employment.

In addition, under circumstances of suspicious behaviour, allegations and/or investigations relating to bribery or corruption, Adipven reserves all rights to request the relevant Employee to declare information regarding assets owned as deemed necessary.

14. Anti-bribery and Anti-Corruption compliance

The Managing Director and the Directors shall have the oversight of the implementation of compliance controls related to The Policy. The Managing Director and the Directors shall conduct regular risk assessments to identify the bribery and corruption risks potentially affecting Adipven.

The Managing Director and the Directors shall also review the suitability of The Policy from time to time, taking into account relevant developments in the legislature as well as evolving industry and international standards.

The Managing Director and the Directors shall implement and effectively manage routine anti-bribery and anti-corruption measures as deemed appropriate to ring-fence Adipven against possible legislative liabilities, as well as undertake ad-hoc measures deemed required based on circumstantial requirements that presents during the course of operations.

15. Awareness and training

Adipven shall conduct awareness programmes for all Employees to refresh awareness of antibribery and anti-corruption measures, and to continuously promulgate integrity and ethics. In addition, Adipven provides anti-bribery and anti-corruption training to new recruits and, Employees promoted / transferred to Exposed Positions.

The Managing Director and the Directors may at any time recommend that certain trainings be repeated to any Employee if deemed necessary based on circumstantial requirements.

Adipven’s Human Resources Department shall maintain all records of trainings.

 16. Reporting of policy violations

Employees who encounter actual or suspected violations of The Policy are required to report their concerns. Each Employee has a responsibility to ensure that suspected bribery and corruption incidents are reported promptly. Adipven practices an open door policy and encourages all Employees to share concerns and suggestions with superiors and colleagues who are able to address them in an appropriate manner.

The Policy sets out secured whistleblowing to the Managing Director and the Directors via their respective working email.

Reports made in good faith, either anonymously or otherwise, shall be addressed in a timely manner and without incurring fear of reprisal regardless of the outcome of any investigation.

17. Non-compliance

The Managing Director and the Directors shall conduct regular validation to ensure compliance to this Policy. Such validation exercises may be conducted either independently by the Managing Director and the Directors or conducted by external consultants.

Non-compliance identified by the validation or identified through other risk assessments undertaken shall be reported to the Managing Director and the Directors.

18. Continuous improvements

Adipven is committed to continually improving its policies and procedures relating to anti-bribery and anti-corruption. Adipven may therefore endeavour to develop further integrity measures and certify Adipven’s anti-bribery procedures as adequate where certification is available.

19. Sanctions for non-compliance

Adipven regards bribery and corruption as a serious matter. Non-compliance may lead to disciplinary action, up to and including termination of employment. Further legal action may also be taken in the event that Adipven’s interests have been harmed as a result of noncompliance.

Adipven shall notify the relevant regulatory authority if any identified bribery or corruption incidents have been proven beyond reasonable doubt.

Where notification to the relevant regulatory authorities have been done, Adipven shall provide full co-operation to the said regulatory authorities, including further action that such regulatory authority may decide to take against convicted Employees.

20. Waiver

Any deviation or waiver from The Policy must be approved the Managing Director and the Directors.