Anti-Bribery & Corruption Policy

Effective date: January 1, 2024

We are committed to conducting our business with integrity and in compliance with all applicable laws and regulations. As part of this commitment, we have established a robust anti-bribery and corruption policy to guide our employees, partners, and stakeholders in upholding the highest ethical standards.

Definition of Bribery: Bribery is the offering, promising, giving, demanding, or receiving of an undue advantage (financial or non-financial) to influence a person in their duties or to obtain an improper advantage. This can be done directly or indirectly, and through a third party.

Prohibited Activities:

Offering, promising, or giving bribes to any party, including government officials, business partners, or individuals.
Soliciting, demanding, or accepting bribes from any party.
Engaging in facilitation payments (payments to expedite routine government actions).
Offering or accepting gifts, entertainment, or hospitality that is excessive or could be perceived as an attempt to influence a business decision.
Engaging in any other activity that violates anti-bribery or corruption laws.

Expectations for Employees and Third-Party Representatives:

All employees and third-party representatives acting on our behalf are required to comply with this policy.
Employees must avoid any situations that could create a conflict of interest or the appearance of impropriety.
When dealing with government officials, business partners, or other third parties, employees must always act with transparency and integrity.

Gifts and Entertainment:

Offering or accepting gifts or entertainment must be reasonable and infrequent, and never with the expectation of influencing a business decision.
Prior approval is required for offering or accepting any gifts or entertainment that exceeds a predetermined value.

Political and Charitable Contributions:

All political and charitable contributions must comply with applicable laws and regulations.
Contributions should be made in a transparent manner and not used to obtain an unfair business advantage.

Reporting Bribery

We encourage all employees and third-party representatives to report any suspected violations of this policy.
Reports can be made anonymously through our confidential reporting hotline or directly to a supervisor, manager, or compliance officer.
The Company will not tolerate retaliation against anyone who reports a suspected violation in good faith.

Investigation and Enforcement

All reported violations of this policy will be investigated thoroughly and objectively.
Any employee found to have violated this policy will be subject to disciplinary action, up to and including termination of employment.
The Company may also take legal action against any party involved in bribery or corruption.

Training and Communication

The Company will provide regular training to employees on this policy and best practices.
This policy will be communicated to all employees and third-party representatives.

We are committed to fostering a culture of integrity and transparency throughout our organization. By adhering to this Anti-Bribery Policy, we can help ensure that our business practices are ethical and compliant with the law.

If you have any questions about this policy, please contact us at info@ximnet.com.my.