The INK MARKETING SDN BHD Anti-Bribery Policy is established to provide clear guidelines to all employees regarding any situation involving bribery. The company has zero tolerance for bribery and conducts business transactions in an ethical manner. To clarify, a “bribe” is anything of value, including cash payments, gifts, entertainment or other business courtesies, given in an attempt to affect a person’s actions or decisions in order to obtain or retain business or to secure an unfair business advantage. It is important to remember that engaging in bribery, or even appearing to engage in such activity, can expose you and our company to criminal liability.

 

 POLICY OBJECTIVES

The objective of the company’s documented policies is to provide an overview of expectations for employees. No policy can address every situation; employees are expected to use sound judgment in complying with the spirit of the policy.

In addition, the Anti-Bribery Policy exists to:

01    Inform employees any form of bribery is not acceptable.

02    Provide guidance to employees who are put in a situation where bribery may be involved.

03    Maintain high standards of business transactions.

04    Prohibit actions intended either to influence a specific decision or merely to enhance future relationships.

 

 POLICY SCOPE

This applies to all INK Marketing employees worldwide, anyone doing business for or with INK Marketing and others acting on the company’s behalf. Applies to all locations where INK Marketing conducts business and to all company-sponsored events. This policy may be augmented by related jurisdictional laws as well as process policies and procedures; the stricter policy or law applies.

 

 GUIDELINES

01    INK Marketing with all applicable anti-bribery laws and accurately reflects all transactions on the company’s books and records.

02    INK Marketing believes in ethical business practices.

03    Third parties acting on our behalf, such as agents or consultants, must never offer, give, accept or receive, directly or indirectly, a bribe in any form.

04    The acceptance of any form of bribe by an individual compromise the position of the company and will be treated as a serious disciplinary matter.

05    We prohibit improper payments to government officials, regardless of where we are located.

 

COMPLIANCE

Employees are expected to comply with this and all applicable INK Marketing policies. Violation of this policy or the refusal to cooperate will result in disciplinary action, up to and including termination and referral to the appropriate authorities, as warranted.

Specific to this policy, employees are expected to:

01    Never accept any form of bribery.

02    Never bribe any customer, vendor, supplier or other individual to per sway decisions.

03    Never offer, pay, make, seek or accept a personal payment, gift or favour in return for favourable treatment or to gain any business advantage.

04    Keep accurate books and records so that payments are honestly described, and company funds are not used for unlawful purposes.

05    Never directly or indirectly promise, offer or make payment in money or anything of value to anyone, including a government official, agent or employee of a government, political party, labour organisation or business entity or a candidate of a political party, or their families, with the intent to induce favourable business treatment or to improperly affect business or government decisions.

06    Never attempt to induce a local or foreign official to do something illegal.

07    Never “shrug off” or fail to report any indication of improper payments.

08    Refuse any demand for a bribe.

09    Report any instances to a manager where bribery has occurred.

10    Never permit an agent or representative of the company to take questionable actions (‘looking the other way’).

RESPONSIBILITIES OF EMPLOYEES

Employees are responsible for understanding and complying with this Policy. The role of all Employees includes the following:

1. Be familiar with applicable requirements and directives of the policy and communicate them to subordinates;
2. Promptly record all transactions and payments accurately and in reasonable detail;
3. Always raise suspicious transactions to immediate superiors for guidance on next course of action;
4. Promptly report violations or suspected violations through appropriate channels
5. Promptly complete COBC trainings and assessments, as well as attest to comply annually.