ANTI-BRIBERY & CORRUPTION

ANTI-BRIBERY & CORRUPTION POLICY

 

NANYANG SYNERGY SDN BHD (hereinafter “NY”, “the Company”) is committed to conducting business dealings with integrity, transparency, and accountability. The Company has adopted a zero-tolerance approach against all forms of bribery and corruption.

1.          Bribes

 

Employee shall not offer, give, ask for, accept, or receive any form of bribe, facilitation payment or undue or improper advantage, favour, or incentive to/from any business partner representatives, government officers, or any other third party (either in the private or public sector), whether directly or through an intermediary.

2.          Gifts

 

Employee must not offer or receive any gift which could be regarded as illegal or improper influencing recipient’s decision from or to business partner representatives, government officers, and other parties engaging with NY, unless:

  • The value of gifts is not exceeding RM 200 with the prior approval of the Company’s management.

3.          Hospitability

 

Hospitality may come in many forms such as meals, entertainment, and recreation (leisure activities).

Employee may offer or accept hospitality of business partners such as luncheon or dinner for business related purpose, provided it could not reasonably be perceived influencing professional judgement, otherwise it must be paid by the Company.

4.          Conflicts of Interest

Conflicts of interest arise in situations where there is personal interest that could be considered to have potential interference with objectivity in performing duties or exercising judgment on behalf of the Company.

All Employee should avoid situations in which personal interest could conflict with their professional obligations or duties.

In situations where a conflict does occur in business dealing, the Company management will declare such potential conflict of interest to business partners. Employee are required to declare the matter to immediate superior and Human Resource.

5.          Money Laundering

 

The Company prohibits practices related to money laundering, including dealing in the proceeds of criminal activities. All business and commercial dealings are transparently performed and accurately recorded in the financial transaction records. The Company will take reasonable steps to prevent and detect any illegal form of payments and prevent its financial transactions from being used by others to launder money.

6.          Insider Dealing

The Company management and employee shall protect the confidential business information of business partners and never use it for own benefit or gain from the possession of such information.

7.          Facilitation Payments

 

Facilitation payments are a form of bribery made to expedite or facilitate the performance of a public official for a routine governmental action, to obtain or retain business or any improper business advantage.

All employees are disallowed to make such facilitation payments.

8.          Competition

NY shall always meet competitors in an honest and professional manner. The Company management shall not cause or be part of any breach of applicable competition laws and regulations, such as illegal cooperation on pricing and illegal market sharing.

Whistleblowing

Employees, suppliers, contractors, and the public are encouraged to report any attempted, suspected, and actual misconduct such as bribery, corruption, fraud and etc to the following channels:

Email: nys@nanyang-synergy.com

 
Mobile: +60 4-5081789

Referring to Authorities

Once receipt of the report, the Management will take the following actions:

  • Conduct investigation by Management/Committee internally or through a disciplinary process;

  • Refer to authorities (i.e Police) if there are criminal elements;

  • Report to NY’s business partner if it is found in breach of their code of conduct which the management is obligated to comply.