IDEASPARQ ROBOTICS SDN BHD (hereinafter referred to as ‘the Company’) is committed to conducting business dealings with integrity. This means avoiding practices of bribery and corruption of all forms in the Company’s daily operations. 

​

This policy shall set up the Company’s zero tolerance approach against all forms of bribery and corruption and takes a strong stance against such acts. 

Employees who refuse to pay or receive bribes or participate in acts of corruption will not be penalised even if such refusal may result in the Company losing its business or not meeting the targets.

 

1. OBJECTIVE

1.1 This Policy sets out the Company’s position on bribery in all its forms and matters of corruption that might confront the Company in its day-to-day operations.

 

2. APPLICABILITY

2.1 This Policy is applicable to anyone who is employed by or work at the Company (whether in Malaysia or outside Malaysia and whether  permanent, fixed-term or temporary basis), directors, company secretaries and committee members (hereinafter referred as ‘Our  Personnel’). It is also applicable to contractors, sub-contractors, consultants, agents, representatives and service providers of any kind performing work or services, for or on behalf of the Company (hereinafter referred as ‘Business Partners’).

 

3. ADOPTION OF MEANING OF ‘GRATIFICATION’ UNDER SECTION 3 OF THE MALAYSIAN ANTI-CORRUPTION COMMISSION ACT 2009

3.1 For the purpose of this policy, the Company adopts the meaning of ‘gratification’, as being the subject matter of any act of bribery and corrupt practices as defined in Section 3 of the Malaysian Anti-Corruption Commission Act 2019 (Act 694) which includes; 

 

(a) 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; 

(b) any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity; 

(c) any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part; 

(d) any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage; 

(e) any forbearance to demand any money or money’s worth or valuable thing; 

(f) 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 

(g) any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f); 

 

4. ANTI-BRIBERY AND ANTI-CORRUPTION POLICY 

4.1 The Company upholds a zero-tolerance approach and prohibits all forms of bribery and corrupt practices. In addition to bribery, Our Personnel must not participate or become the instrumentalities of any corrupt activity, such as extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering. 

4.2 Bribery may take the form exchange of money, goods, services, property, privilege, employment position or preferential treatment. Our Personnel are prohibited to 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 an organisation, either for the intended benefit of the Company or the persons involved in the transaction. 4.3 This Policy applies equally to its business dealings with commercial (‘private sector’) and government (‘public sector’) 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. 

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

4.5 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 the Company losing business or experiencing a delay in business operations. 

4.6 The Company recognises the value of integrity in its employees. The Company’s recruitment, training, performance evaluation, remuneration, recognition and promotion for shall be designed to recognise integrity. 

4.7 The Company does not offer employment to prospective employee in return for previous favour/in exchange of improper favour. 

4.8 The Company 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. 

 

5. COMPLIANCES TO SECTION 17A OF MALAYSIAN ANTI-CORRUPTION COMMISSION ACT 

5.1 With the enforcement and implementation of Section 17A of Malaysian Anti-Corruption Commission Act 2009 by June 2020, the Company is required by law to ensure that its business practices and operations adhere to the requirements of the Act. 

5.2 The Company’s employees, agents, business partners and contractors under contract for services in the course of performance of their duties and services to, for and/or on behalf of The Company, are prohibited to corruptly gives, agrees to give, promises or offers to any person any gratification (meaning of ‘gratification’ as defined under Section 3 of Malaysian Anti-Corruption Commission Act 2009) whether for the benefit of that person or another person with intent:

 

(a) to obtain or retain business for the Company ; or 

(b) to obtain or retain an advantage in the conduct of business for the Company. 

 

6. FACILITATION PAYMENTS 

(a) Facilitation payments are form of payments made personally to an individual in control of a process or decision to secure or expedite the performance of a routine or administrative duty or function (e.g., influencing the timing of process or issuing of permits). In Malaysia, facilitation payment is illegal. It is seen as a form of corruption. Regardless of whether it is legal in any other country, facilitation payment is strictly prohibited under this Policy. 

(b) Our Personnel and Business Partners are prohibited either directly or indirectly to offer, promise or give any form of facilitation payment to any public officials for any purposes. 

(c) There may be occasion where an employee may be forced to make facilitation payments in order to protect his life, limb or liberty. In such occasion, the particular employee must immediately report the incident to management and/or any senior officer of the company for the necessary action to be taken.

 

7. GIFT 

A. Providing Gift 

7.1 The Company prohibits both the giving and receiving of gifts to influence business decisions. However, under limited and specific circumstances, the Company may authorize corporate and festive or ceremonial gifts to foster good relationship between the Company and its Business Partners or other parties. 

7.2 The Company’s corporate gift normally bears the company’s name and logo and are of nominal / appropriate value such as diaries, table calendars, pens, notepads and plaques. Festive or ceremonial gifts are traditional treats or gifts customary to the occasion such as oranges and dates. 

7.3 Corporate gifts, festive or ceremonial gifts may be given to our Business Partners or other parties provided it fulfils all of the following conditions:

 

(a) made for the right reason – it should be clearly given as an act of appreciation or common courtesy associated with festive seasons or other ceremonial occasions; 

(b) no obligation – it must not be used to cause or induce the receiver to improperly or illegally influence any business action or inaction or cause others to perceive an improper influence; 

(c) no expectation – there must not be any expectation of any favour or improper advantages from the receiver; 

(d) made openly – if made secretly and undocumented then the purpose will be open to question; 

(e) reasonable value – the type of gift and its value must commensurate with the occasion and in accordance with general business practice; 

(f) legal – it complies with applicable laws; and 

(g) documented – the expense must be approved in accordance with and complies with the Company’s standard operating procedures. 

(h) reasonable value – the type of gifts and its value must commensurate with the occasion and in accordance with general business practice. 

 

B. Accepting Gift 

7.4 The Company recognises that exchange of gifts is a very delicate matter where, in certain cultures or situations, gift giving is customary, a tradition or central part of business etiquette. 

7.5 Our Personnel are expected to decline (or avoid accepting) gifts with the exceptions being: 

 

(a) corporate gifts of nominal / appropriate value; 

(b) festive or ceremonial gifts of appropriate value during festive seasons or other ceremonial occasions; 

(c) when refusing the gift is likely to offend and harm the Company’s business relationship with the giver; or 

(d) gifts given during invitation to speak at conferences or work-related conferences.

 

If employees are in doubt about the acceptability, the gift must be refused. 

7.6 Our Personnel and Business Partners must not directly or indirectly solicit for gifts from any party for themselves or for or on behalf the Company. Our Business Partners are strictly prohibited to give gifts to Our Personnel. 

7.7 Our Personnel must record any gift received, irrespective of value, in the Gifts Register within five (5) working days of receipt. In no circumstances may Our Personnel (or anyone on their behalf) accept gift in the form of cash or cash equivalent.

 

8. CORPORATE HOSPITALITY 

Corporate hospitality is generally corporate events or activities organised by an organisation, which involves entertainment of employees and/or other parties for the benefit of that organisation. Examples of corporate hospitality includes seminars / workshop / talks on subject matters relevant to the industry and town hall sessions. Other parties may include customers, contractors, consultants, bankers, lawyers, service providers of any kind, stakeholders with whom a business relationship (whether past, present or prospective) exists and the public at large.

 

i. Providing Corporate Hospitality 

(a) The Company recognises that providing corporate hospitality be it through corporate events, sport events or other public events, is a legitimate way to network, promote goodwill and build business relationships. 

(b) While providing appropriate and proportionate corporate hospitality is a reflection of the Company’s courtesy and generosity, Our Personnel must exercise proper care and good judgement to ensure that the arrangement is legal under applicable laws, made for the right reasons and reasonable in its form and limit. More importantly, it must not be given or give rise to the perception that it is given to obtain business or advantage of any kind or unduly influence the outcome of a business decision. 

 

ii. Accepting Corporate Hospitality 

(a) As a general principle, Our Personnel must not directly or indirectly solicit corporate hospitality or accept corporate hospitality of any form that is excessive, inappropriate, illegal or given in response to, in anticipation of, or to influence a favourable business decision. 

(b) Notwithstanding the above, the Company recognises that occasional acceptance of an appropriate level of corporate hospitality given in the normal course of business is usually a legitimate contribution to building good business relationships. However, Our Personnel must exercise proper care and good judgement to ensure that the arrangement is legal under applicable laws, made for the right reasons and reasonable in its form and limit. More importantly, it must not be accepted or give rise to the perception that it is accepted to obtain business or advantage of any kind or unduly influence the outcome of a business decision.

 

9. DONATIONS AND SPONSORSHIPS 

9.1 Prohibition of Donation / Contribution to Political Parties or Individual Politicians; 

Our Personnel and Business Partners must not make donation or funding of any kind to political parties or individual politicians or towards political campaigns or initiatives for or on behalf of the Company. 

9.2 Charitable or Educational Donations and Sponsorships; 

The Company will only provide charitable or educational donations and public welfare sponsorships if they are ethical and legal under applicable laws. All donation and sponsorship expenses must be approved in accordance with the Company’s standard operating procedures. Our Personnel and Business Partners must never use donations or sponsorships to obtain business or advantage of any kind or unduly influence the outcome of a business decision or cause others to perceive it as such. The use of donations or sponsorships in this manner is strictly prohibited under this Policy.

 

10. CONFLICTS OF INTEREST 

10.1 Conflicts of interest arise where there is personal interest that can be considered to have potential interference with objectivity in performing duties or exercising judgement for or on behalf of the Company. Our Personnel and Business Associates must avoid situations in which their personal interest would conflict with their duties and responsibilities. They must not use their position, official working hours, the Company’s resources and assets, or information available to them for personal gain or to the Company’s disadvantage. 

10.2 In situations where conflict of interest arises, Our Personnel are required to immediately declare the matter to their immediate superior and/or management. 

 

11. DEALING WITH GOVERNMENTS AND PUBLIC OFFICIALS 

(a) Our Personnel and Business Partners must comply with all applicable laws, conduct themselves with integrity and apply the highest ethical standards 

(b) whenever they deal or otherwise engage with governments, government agencies, regulatory bodies, statutory bodies (whether local or foreign) and any of its officials. 

(c) The Company shall follow and adhere to Pekeliling Perkhidmatan Bilangan 3 Tahun 1998 – Garis Panduan Pemberian dan Penerimaan Hadiah Di dalam Perkhidmatan Awam with regards to providing gifts to government agencies, regulatory bodies, statutory bodies and any of its officials. 

(d) Any form of gift to the governments, government agencies, regulatory bodies, statutory bodies (whether local or foreign) and any of its officials which and/or who is directly having official duties with the Company is strictly prohibited. 

(e) Our Personnel or Business Partners must not directly or indirectly exert, or attempt to exert, any improper or illegal influence on public officials. 

(f) If any information is required by any government, government agencies, regulatory bodies, statutory bodies (whether local or foreign), Our Personnel must always consult their immediate supervisor before responding to such requests and ensure that all information provided is in good faith, truthful and accurate.

 

12. ENTERTAINMENT 

A. Providing Entertainment 

(a) It is a common practice within the business environment to provide entertainment to foster business relationship. The Company recognises the need to provide reasonable and proportionate entertainment under appropriate circumstances. Employees and Our Personnel may offer appropriate and proportionate entertainment that is legal and reasonable within the scope of their work as part of business networking as well as a measure of goodwill towards the recipients. 

(b) Whilst the act of hospitality through entertainment is a central part of business etiquette, it may create a negative perception if observed or known by others despite selfless motives behind the entertainment provided. Employees and Our Personnel must always bear in mind that perception is more important than facts and therefore Our Personnel are expected to always exercise proper care and good judgement when providing entertainment to external parties, especially when it involves public officials. 

(c) Our Personnel must not directly or indirectly provide or offer to provide entertainment with a view to cause undue influence or in exchange for favours or advantages. Such acts are considered corruption. 

 

B. Accepting Entertainment 

(a) The Company recognises that occasional acceptance of appropriate and proportionate entertainment provided by Business Partners or other parties in the normal course of business is a legitimate way to network and to build business relationships. 

(b) However, it is important for Our Personnel to exercise proper care and good judgement before accepting entertainment offered or provided by Business Partners or other external parties. This is to safeguard the Company’s reputation and avoid allegations of impropriety or undue influence or worse, corruption. 

(c) Our Personnel must at all times conduct themselves with integrity in relation to accepting entertainment from any party. Employees or any of their family members must not accept entertainment in exchange for an exercise or non-exercise of their job function or activity. 

 

13. TREAT 

13.1 The Company’s employees, on occasions, are allowed to provide treat (whether breakfast, lunch, high tea etc) to Business Partners, clients and government officials. However, due considerations must be given to these factors; 

(a) The treat must not be in furtherance of any corrupt intention and to influence the decision of the Business Partners, clients or government officials; 

(b) The amount of treat must be reasonable and must not give rise to negative and/or scandalous perception from the public. 

 

13.2 In the event the treat is given to any government officials, it is important to take into accounts these factors; 

(a) The action must not result in dereliction and influence on the official powers and duties of the government officials towards the Company; 

(b) The manner of treat provided must not go against the required behaviours and conducts of the public officials; 

(c) The treat must not offend the government official’s departmental sensitivities; 

(d) The treat must not offend the societal sensitivities towards duties and responsibilities of public officials; and 

(e) The treat can only be given once in a while. 

 

14. ENFORCEMENT FOR NON-COMPLIANCE 

14.1 The Company regards acts of bribery and corruption seriously and will take appropriate actions in the event of non-compliance of this Policy. For Our Personnel, noncompliance of this Policy may lead to disciplinary action and termination of employment. The Company may also engage with the relevant law enforcement agencies to assist the company to conduct a thorough and proper investigations when there are suspicions of corrupt practices which involved the Company’s employees. 

14.2 For Business Partners, non-compliance of this Policy may lead to termination of contract. 

 

15. TRAINING AND COMMUNICATIONS 

15.1 This Policy is a public document which shall be communicated to all Our Personnel and Business Partners. Our Personnel and Business Partners must read and understand the Company’s position on anti-bribery and anti-corruption. 

15.2 Adequate training on the Company’s anti-bribery and anti-corruption approach shall be provided to Our Personnel. 

 

16. WHISTLEBLOWING CHANNEL 

16.1 If you suspect, or reasonably believe that this Policy has been, or is being breached, you have an obligation to report your concerns to the management and where applicable. 

16.2 All concerns reported will be taken seriously, treated in confidential manner and investigated immediately. Your anonymity will be protected unless the disclosure is required by law pursuant to an investigation or legislation, but you may be required to provide a statement as supporting evidence to any investigation. Any retaliation directed against anyone making such report will not be tolerated. 16.3 All reports shall be made in good faith and the report must be legitimate. Anyone who makes any malicious, scandalous or vexatious report, and particularly if they persist with such untrue allegations, they will be subjected to the Company’s disciplinary actions. 

 

17. REGULAR MONITORING AND REVIEW 

17.1 The Company is committed to making the anti-bribery and anti-corruption effort as a continuous effort to maintain the reputation and standards of the Company. 

17.2 Regular audits shall be conducted to monitor, review, improve and assess performance, efficiency and effectiveness of ongoing anti-bribery and anti-corruption efforts by the Company. Such audits may be conducted internally by the Company or by an external party. 

17.3 Our Personnel is encouraged to raise any concerns or inadequacies in the anti-corruption compliance programme to the management.

 

18. POLICY TO BE REVIEWED REGULARLY 

18.1 The Company shall review and amend this Policy from time to time to include the latest updates, regulations and laws in force and the best practices in combating corruption.