- Anti-Bribery & Corruption Policy
Fishbowl Ventures Sdn Bhd and its subsidiaries – (“the Fish Bowl group/the Company”) is committed to conducting its business with the highest ethical standards and in compliance with all applicable laws and regulations in Malaysia, including the Malaysian Anti-Corruption Commission Act 2009, as amended by the Malaysian Anti-Corruption (Amendment) Act 2018 (“MACC Act”), as well as other relevant laws and regulations. This Anti-Bribery & Corruption Policy (“Policy”) outlines our zero-tolerance approach to bribery and corruption and sets forth the standards and procedures to prevent, detect, and respond to any form of bribery and corruption.
- Purpose
The purpose of this Policy is to:
- Ensure compliance with the MACC Act and other relevant laws.
- Provide guidance on recognizing and dealing with bribery and corruption.
- Promote a culture of integrity and accountability within the Company.
- Protect the Company’s reputation and interests
- Scope
This Policy applies to all employees, directors, officers, agents, consultants, contractors, suppliers and any other third parties acting on behalf of the Company (“Covered Persons”).
- Definition of Bribery and Corruption
Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of an individual in a position of trust in the performance of their duties.
Corruption: Abuse of entrusted power for private gain, including but not limited to bribery, extortion, fraud, collusion, and money laundering.
- Prohibited Conduct
Covered Persons are prohibited from:
- Offering, promising, giving, or authorizing any bribe, kickback, or other form of improper payment, directly or indirectly, to any individual or entity, including government officials, to influence any act or decision.
- Soliciting, accepting, or receiving any bribe, kickback, or other form of improper payment, directly or indirectly, in connection with any business activity.
- Engaging in any form of corruption, including but not limited to extortion, fraud, collusion, or money laundering.
- Gifts, Hospitality, and Entertainment
While the Company recognizes that the exchange of gifts, entertainment, and hospitality can be a legitimate part of building business relationships, Employees must ensure that these are not used to gain an improper advantage. All gifts, entertainment, and hospitality must be:
- Reasonable and proportionate: They should not be lavish or extravagant.
- Transparent: They must be openly given and documented.
- Permitted by law: They must comply with all relevant laws and regulations.
- Charitable Donations and Sponsorships
The Company supports charitable donations and sponsorships that are legal and ethical. However, such donations and sponsorships must not be used as a means to conceal bribery or corruption. All charitable donations and sponsorships must be approved by the appropriate level of management.
- Political Contributions
The Company does not make political contributions. Covered Persons are prohibited from using Company funds or resources to make any political contributions on behalf of the Company.
- Due Diligence
The Company will conduct appropriate due diligence on third parties, including agents, consultants, and contractors, to ensure they comply with anti-bribery and corruption laws and this Policy.
- Reporting and Whistleblowing
Covered Persons are required to report any suspected or actual bribery or corruption to the Company’s Compliance Officer or through the whistleblowing hotline. The Company will protect whistleblowers from retaliation and ensure that all reports are investigated promptly and thoroughly.
- Training and Communication
The Company will provide regular training on anti-bribery and corruption to all Covered Persons. This Policy will be communicated to all employees, directors, officers, agents, consultants, contractors, and other third parties acting on behalf of the Company.
- Monitoring and Review
The Company will regularly monitor and review the effectiveness of this Policy and the compliance program. Any necessary updates to this Policy will be made to ensure it remains relevant and effective.
- Consequences of Non-Compliance
Non-compliance with this Policy may result in disciplinary action, including termination of employment or contract, and may also result in legal action.
- Contact Information
If you have any questions about this Policy, please contact us at [email protected]
