ANTI-BRIBERY AND ANTI-CORRUPTION

POLICY STATEMENT

Advance Synergy Realty Sdn. Bhd. Company No. 198001004014 (57798 – H) (hereinafter referred to as “ASR”), recognises the importance of establishing and upholding good corporate governance and is committed to conducting its business in accordance with the highest ethical standards in full compliance with all applicable laws, regulations and standards in all locations and jurisdictions in which ASR operates. This reputation had been created by our organisational values and the values of our employees, therefore, having a collective commitment to promote ethics and integrity. As part of our commitment to ethical business practices, ASR shall not participate or condone any acts or forms of bribery or corruption.

In line with this commitment, ASR adopts a “zero-tolerance approach” towards any form of bribery and corruption in conducting its business. This principle is that any form of bribery and/or corruption as an inducement or a pecuniary reward that has been offered, promised and provided in order to gain any commercial, contractual, regulatory or personal advantage is not acceptable.

The ASR’s Anti-Bribery and Anti-Corruption Policy (“ABAC Policy”) applies to all ASR officers and directors of ASR, employees (whether permanent or temporary basis), contractors, its subsidiaries and joint venture companies under ASR’s control. Third parties acting on behalf of or in the name of ASR, including agents, representatives and other intermediaries, are required to act consistently with ASR’s Anti-Bribery Policy. Joint venture companies not under ASR’s control, and our joint venture partners, are encouraged to adopt a similar policy and procedures to prevent bribery. All employees and personnel are to refrain from offering or receiving any gifts, entertainment, hospitality and non-business travel to/from external party in the course of their duties as it may put them in an obligated or compromised position which could affect business judgement.

Any non-compliance with ASR 's ABAC Policy requirements by the personnel, employees, or agents will be treated as grounds for disciplinary action, dismissal or termination. ASR reserves its right to report such matters to the relevant enforcement authorities for their further action.

Any personnel, employee or external party, with a business relationship with ASR, who suspects that a form of bribery or corruption has occurred or that there has been a breach of the ABAC Policy, can report such suspected incidents via ASR’s whistleblowing channel. All information will be treated with strict confidentiality.

ASR’s Whistleblowing Channel ASR has put in place the Whistleblowing Policy and Procedures to provide an avenue which serves as a confidential platform for all personnel, employees, agents and/or third parties to disclose any acts of bribery and/or corruption in a confidential manner that protects the whistleblower from any risk of reprisals.

Our whistleblowing form can be downloaded (file size 1.72 Mb).

The Whistleblowing form can be submitted via email at asrkch@hotmail.com or to the Whistleblowing Committee via post.

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