Anti-Bribery & Anti-Corruption Policy

POLICY STATEMENT

State practices a ‘ZERO TOLERANCE’ policy against all forms of bribery and corruption.

State and all the employees are committed to constantly uphold the highest standards of professional integrity and ethical conduct at all times when performing business activities and comply with the Malaysian Anti-Corruption (MACC) Act 2009, subsequent amendments to the Act and all guidelines issued by relevant authorities pertaining to the same.

SCOPE AND COVERAGE

This Policy applies to all employees, business associates, and third parties, which include customers, suppliers, agents, consultants, outsourcing providers, advisers and other representatives.

This policy sets forth the minimum compliance standards to which all employees of State must adhere to at all times.

State also expects all third parties engaged by State or performing work or services for or on behalf of State will comply with this policy when performing such work or services.

COMBATING BRIBERY, CORRUPTION AND UNETHICAL ACTIVITIES

1. Solicitation, Bribery and Corruption

Employees are refrain, directly or indirectly, to solicit, pay, offer, accept or receive a bribe in any form in connection with any business or anticipated future business involving State. Employees are strictly not allowed to:

a. Promise, offer, pay or give a bribe to anyone
b. Request, accept or take a bribe from anyone
c. Act corruptly and illegally in dealings with any person
d. Give some advantage inconsistent with law and wrongful or unlawful use of official position to procure some benefit or personal gain
 

2. Conflicts of Interest

Conflicts of interest happens when any person or company is involved in multiple interests, which could possibly corrupt, or be viewed to corrupt. A conflict of interest may be actual, potential or perceived and may be financial or non-financial.

It is the responsibility of State and all the employees that any ethical, legal, financial or other conflicts of interest be avoided.

3. Gifts and Hospitality

The gifts and hospitality, whether they are given or received, are allowed only if they are reasonable, not lavish, appropriate and consistent with the business and industry practice.

Employees should exercise sound judgment and are required to comply with the Receiving and Giving of Business Gift Guideline set forth by State.

4. Donations and Sponsorships

Donations and sponsorships are not to be used as a means for bribery.
All donations and sponsorships can only be made or received from any party provided:

• such contributions are appropriate and comply with all legal requirements
• they are not made to secure any improper business or other advantage
• they have been subjected to due diligence and management approvals
 

No political donations or payments are allowed.

WHISTLEBLOWING AND REPORTING OF A CONCERN

To encourage openness and transparency, we have provided an accessible and trusted channel for all employees of State, members of the public and all third parties engaged by State, to disclose or report any suspected or improper conduct in relation to anti-bribery and corruption.

All disclosures or reports can be channelled via email to the Integrity Team of State at whistleblowing@state.com.my.