Anti-Bribery and Corruption Policy

(hereinafter referred to as the “Policy”)

POLICY STATEMENT

At WASTECH GROUP SDN. BHD. (Formerly known as WASTECH RESOURCES SDN. BHD.) (Registration No. 202001024061 (1380381-V)) along with our subsidiaries, affiliates, its associated company(ies), its joint venture partners, including but not limited to all of its shareholder(s), its director(s), its employee(s), its supplier(s), its contractor(s) and/or its permitted person(s) (hereinafter referred to as “we”, “our”, “us” or “WASTECH”), are committed to apply the highest standards of ethical conduct and integrity in its business activities in the market it operates in.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all of our business dealings and relationships wherever we operate. We will ensure that every director, employee and person acting on WASTECH’s behalf to perform their duties objectively and ethically and not to do anything and act in any manner which will cast doubts or suspicions over WASTECH’s commitment in combating bribery and corruption or the attempt thereof.

There will be no waivers or exceptions granted for conducts that depart from or contrive from this Policy. Any violation of this Policy may result in disciplinary action, up to and including dismissal under appropriate circumstances. It is therefore extremely important that you familiarise yourself with this Policy and strictly adhere to it.

1. APPLICATION AND DEFINITION
  1. Application
    This Policy is applicable to every LEVEL of WASTECH’s employees, including the top management, senior management, head of departments and staffs. If any employees require further clarification on the Policy, the employee may refer their queries to WASTECH’s respective Compliance Department.

    Although this Policy is written specifically for all level of employees under WASTECH, we call upon all of our vendors, contractors, consultants, agents, representatives and other third parties performing work and/or service for or on behalf of WASTECH as well as all customers and other third parties receiving work and/or services from WASTECH to observe this Policy and act in accordance with this Policy, at all times, when dealing with us.

  2. Definition
    The following terms shall have the following meanings:

    “Act” means the Malaysian Anti-Corruption Commission Act 2009;

    “Bribery” means the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action, which is illegal, unethical or a breach of trust or to refrain from acting;

    “Business Associate” means the party who has or will have business dealings with WASTECH, including but not limited to vendors, suppliers, and contractors;

    “Compliance Department” refers to the Legal and Compliance Department;

    “Corruption” means the abuse of entrusted power for private gain; and

For the purpose of this Policy, the term “bribery and corruption” is used to cover any action which would be considered as an offence under the applicable anti-bribery and corruption laws and regulations and treaties in which WASTECH operates, which includes the Act.

2. BREACH OF POLICY

With reference to the directors or employees of WASTECH, any non-compliance to this Policy may result in disciplinary action, up to and including dismissal in appropriate circumstances. With respect to external parties, non-compliance to this Policy may lead to penalties, including but not limited to termination of contract and/or further legal action to be taken by WASTECH against them.

WASTECH reserves the right to report any actions or activities suspected of being criminal in nature to the police or other relevant authorities.

Please take note that under Section 24 of the Act, any person who is found guilty of corruption may be subjected to imprisonment up to 20 years and a fine of at least 5 times the sum or value of the gratification or RM10,000.00, whichever is higher.

Section 17A of the Act also provides that a company may be held liable if its employees or person who performs services for or on behalf of the company corruptly provides gratification to any person in return for any advantage and may be subject to a fine of at least 10 times the sum or value of the gratification or RM1,000,000.00, whichever is higher, or imprisonment up to 20 years, or both.

A director or senior management of a company may also be deemed to have committed an offence where an offence has been committed by a company under Section 17A of the Act.

3. GIFTS

All directors, employees and/or third parties acting on behalf of WASTECH are prohibited from, directly or indirectly, receiving, providing, or soliciting for gifts, subject only to certain limited exceptions as provided in this Policy.

All directors, employees and/or third parties shall comply strictly with this Policy to avoid any actual or appearance of conflict of interest. A conflict of interest arises when an individual has an interest in any entity or matter that may influence his or her judgment in the discharge of responsibilities.

It is the responsibility of all directors and employees to inform any third parties who have any business dealings with WASTECH of this Policy and to request the third party’s understanding for and adherence with this Policy.

Save for the limited exceptions stated in this Policy, the guidance below should be followed by all directors, employees and/or third parties acting on behalf of WASTECH to:

  1. never offer or accept gifts in the form of cash or cash equivalent, including vouchers, discounts, coupons, shares and commission, or gifts in kind, including free products from Business Associates, such as free tour packages that is not made disclosed, properties, motor vehicles, digital gadgets, computer devices and etc.;
  2. never offer or accept gifts if there is a conflict-of-interest situation;
  3. never offer or accept gifts which you know or suspect to be improper or illegal;
  4. never offer gifts to or accept gifts from parties currently engaged in tender, competitive bidding exercise or contract negotiation;
  5. never offer or accept gifts during periods when important decisions, regarding the award or retention of business, are being made;
  6. never offer or accept gifts offered that comes with a direct or indirect suggestion, hint, understanding or implication that in return for the gifts provided some expected or desirable outcome is required; and
  7. never offer or accept gifts which is in violation of applicable laws.
3.1 Providing Gifts

Generally, all directors and employees are prohibited from providing gifts to third parties save for the limited exceptions below.

The following situations are the limited exceptions where the provision of gifts is permitted:

  1. exchange of gifts at the company-to-company level (e.g. gifts exchanged between companies as part of an official company visit or courtesy call and thereafter said gift is treated as company property);
  2. gifts from WASTECH to third parties and public officials (subject to local rules) in relation to WASTECH’s official functions, events, and celebrations (e.g. commemorative gifts or door gifts offered to all guests attending the event);
  3. gifts from WASTECH to directors and employees and/or their family members in relation to an internally or externally recognised company function, event, and celebration (e.g. in recognition of an employee’s or director’s service to the company);
  4. token gifts of nominal value normally bearing WASTECH’s logo (e.g. t-shirts, pens, diaries, calendars, and other small promotional items) or that are given out equally to members of the public, delegates, customers, partners and key stakeholders attending events such as conferences, exhibitions, training, trade shows etc. and deemed as part of the company’s brand building or promotional activities; and/or
  5. gifts to external parties who have no business dealings with WASTECH (e.g. monetary gifts or gifts in-kind to charitable organisations).

For the purpose of providing gifts under this Policy, prior approval from the management and/or Head of Department is mandatory to do so. Employees of WASTECH in charge of such activity (for this purpose, the said employee is referred to as the “Requestor”) shall be required to fill in the Declaration and Acknowledgement Form [FORM-006-01-WG], including but not limited to, amount, quantities, usage and name of recipients. The Requestor’s department is required to keep a proper stock record of such forms for audit purposes and a copy shall be emailed to legal@wastech.com.my for reference.

3.2 Receiving Gifts

The general principle is to immediately politely refuse or return such gifts and inform the third party of this Policy. Gifts that are deemed as not given to influence the directors’ or employees’ performance of duties include normal business courtesies token gifts which are occasional, gifts during festive or special occasions and gifts from social functions attended by the directors or employees on behalf of WASTECH, are permissible.

Save for the limited exceptions stated in this Policy, the guidance below should be followed strictly by all directors, employees and/or third parties acting on behalf of WASTECH:

  1. gifts are given as an expression of goodwill and not as an expression of a return favour;
  2. gifts commensurate with general accepted standards for hospitality, taking into account the norms for the industry and the country in which it is offered;
  3. gifts are being provided openly and transparently and is of a nature that will not cause WASTECH embarrassment if publicly reported;
  4. comply with applicable laws and regulations;
  5. in the situation where it is impossible to refuse or return the gifts, all directors or employees are expected to immediately record the gift (for any gifts which is of value more than RM500.00) and gain the necessary approval from the management and/or Head of Department. Employees of WASTECH in charge of such activity (for this purpose, the said employee is referred to as the “Recipient”) shall be required to fill in the Declaration and Acknowledgement Form [FORM-006-01-WG], including but not limited to, amount, quantities, usage and name of providers. The Recipient’s department is required to keep a proper stock record of such forms for audit purposes and a copy shall be emailed to legal@wastech.com.my for reference. If in doubts of the value of the gifts, you should always proceed to record such gift and file the said form;
  6. Head of Department will decide on the treatment of the gifts, and will be responsible for the recording of the said gifts;
  7. never receive any gifts privately; and
4. ENTERTAINMENT AND CORPORATE HOSPITALITY

Entertainment is generally defined as the provision of an external event or activity which can pleasurably occupy a person. This may include the provision of meals, transportation and accommodation to third parties.

Corporate hospitality is generally defined as corporate events or activities organised by an organisation which involves the entertainment of employees and third parties for the benefit of that organisation. This may include the provision of meals, transportation, and accommodation to third parties in connection with such corporate events or activities.

Entertainment and corporate hospitality should not be given or received if there is any intention or it could be seen as having any intention to improperly influence the recipient to gain any advantage in return, whether directly or indirectly, for WASTECH or yourself, or as a reward for having acted improperly.

As such, we must ensure that the circumstances in which entertainment and corporate hospitality is offered, given, or accepted are restricted to those which are appropriate and in compliance with applicable laws and regulations, in particular when it involves public officials.

Entertainment and corporate hospitality will be illegitimate in the following situations, and we require that any of our director, employee and person acting on WASTECH’s behalf to immediately refuse it:

  1. entertainment and corporate hospitality offered by parties currently engaged in tender, competitive bidding exercise or contract negotiation;
  2. entertainment and corporate hospitality which you know or suspect to be improper or illegal;
  3. services or favours provided personally, rather than in a business context, unless such services are pursuant to a proper arms’ length business transaction;
  4. entertainment and corporate hospitality for family members, friends or relatives;
  5. entertainment and corporate hospitality during periods when important decisions, regarding the award or retention of business, are being made;
  6. entertainment and corporate hospitality offered that comes with a direct or indirect suggestion, hint, understanding or implication that in return for the entertainment provided some expected or desirable outcome is required;
  7. entertainment and corporate hospitality that may create a sense of obligation, or comes with a direct or indirect suggestions, hint or expectation of special treatment or create a conflict of interest that would be perceived negatively;
  8. any entertainment activities and corporate hospitality activities that would be illegal or in breach of local or foreign bribery laws;
  9. entertainment and corporate hospitality, which is frequent, lavish, or excessive or may adversely affect the reputation of WASTECH; and
  10. any entertainment and corporate hospitality that are sexually oriented and any entertainment at nightclubs.
4.1 Providing Entertainment and Corporate Hospitality

When providing entertainment and corporate hospitality, proper care and good judgment must be taken to protect WASTECH’s reputation against any allegations of impropriety or the perception of bribery and corruption, in particular when the arrangements could influence or be perceived to influence the outcome of a business decision and are not reasonable and bona fide expenditures.

Every director, employee and person acting on WASTECH’s behalf is required to strictly adhere to the following guideline:

  1. all entertainment or corporate hospitality are reported and written approval from management and/or Head of Department is obtained following the limits of authorities and the internal guidelines, all records of which are properly kept. Such record (in the form and format in compliance with WASTECH’s prescribed requirements) shall include information such as name of Business Associate, full name of its representatives and position, information on the entertainment or corporate hospitality provided, purpose and outcome of such entertainment;
  2. the entertainment or corporate hospitality must not be too excessive, lavish or frequent, taking into account the local culture and norms. Furthermore, the entertainment and corporate hospitality must commensurate with the recipient’s official capacity and not provided in his/her personal capacity;
  3. provision of the entertainment or corporate hospitality are done with good and legal intentions;
  4. entertainment and corporate hospitality for family members, friends or relatives;
  5. no personal bias or favouritism involved in the provision of entertainment or corporate hospitality. The entertainment or corporate hospitality must be justifiable and commensurate with the recipient’s position and status;
  6. all expenses incurred to provide the entertainment or corporate hospitality must be within the limits of your entitlement and is properly documented, receipted and recorded in the company’s records;
  7. any entertainment activities or corporate hospitality activities that would involve public officials shall require the prior approval of the management;
  8. no violations of any local anti-bribery and corruptions laws; and
  9. before providing entertainment or corporate hospitality to anyone, consider whether the reputation of WASTECH, yourself, or the recipient is likely to be damaged if news of the entertainment appeared on the front page of a newspaper. If this would embarrass either WASTECH or the recipient, do not proceed.

In view of the foregoing, prior approval from the management and/or Head of Department is mandatory to do so. Employees of WASTECH in charge of such activity (for this purpose, the said employee is referred to as the “Requestor”) shall be required to fill in the Declaration and Acknowledgement Form [FORM-006-01-WG], including but not limited to, amount, quantities, usage and name of recipients. The Requestor’s department is required to keep a proper stock record of such forms for audit purposes and a copy shall be emailed to legal@wastech.com.my for reference.

4.2 Receiving Entertainment and Corporate Hospitality

WASTECH prohibits its director, employee and person acting on WASTECH’s behalf from soliciting entertainment and corporate hospitality that is excessive, frequent, inappropriate, illegal, or given in response to, in anticipation of, or to influence a favourable business decision or any other advantage.

Nevertheless, we recognise that the occasional acceptance of an appropriate level of entertainment and corporate hospitality given in the normal course of business and conform to local cultures and norms is usually a legitimate contribution to building good business relationships. However, it is important for directors and employees to exercise proper care and judgement before accepting the entertainment or corporate hospitality.

You should consider the following questions before accepting any entertainment and corporate hospitality from any third party:

  1. Could my acceptance or offer lead to an obligation for WASTECH or imply an obligation?
  2. Does this entertainment or corporate hospitality seem to be excessive or expensive in any way?
  3. Am I likely to breach any applicable laws, rules, or ethics?
  4. Are there any potential adverse reputational implications in the type of entertainment or corporate hospitality being accepted or given?
  5. Would my colleagues be unhappy to see WASTECH being reported in the press in connection with this entertainment or corporate hospitality?

If the answer to any of these questions is yes, the entertainment and corporate hospitality should not be accepted.

In view of the foregoing, prior approval from the management and/or Head of Department is mandatory to do so. Employees of WASTECH in charge of such activity (for this purpose, the said employee is referred to as the “Requestor”) shall be required to fill in the Declaration and Acknowledgement Form [FORM-006-01-WG], including but not limited to, amount, quantities, usage and name of recipients. The Requestor’s department is required to keep a proper stock record of such forms for audit purposes and a copy shall be emailed to legal@wastech.com.my for reference.

5. FACILITATION PAYMENTS AND KICKBACKS
5.1 Facilitation Payments

“Facilitation Payment” is defined as a payment or other provision made to an individual in control of a process or decision to secure or expedite the performance of duties, for example payments to expedite the issuance of a visa, license, permit or approval or clearing of goods through customs.

WASTECH strictly prohibits receiving, requesting, giving, and promising of facilitation payments, either directly or indirectly, from any person whether for the benefit of WASTECH or the employees personally.

If any person request or give facilitation payments to you, you should politely reject such facilitation payment. This prohibition will not cover official expediting payments pursuant to written regulations or guidelines, for which official receipt is issued and any person could subscribe to such expediting process. You are obliged to ask for an official receipt for any payment you have made. Only in the event an employee’s security is at stake, you are allowed to make such payments. You must immediately report the incident to your Head of Department and Compliance Department to record the details of the incident

5.2 Kickbacks

“Kickbacks” are typically defined as payments made in return for a business favour or advantage.

We strictly prohibit its director, employee and person acting on the WASTECH’s behalf from engaging in any activity that might lead to, or suggest, that a kickback will be made on behalf of WASTECH.

6. CORPORATE SOCIAL RESPONSIBILITY (“CSR”), DONATION AND SPONSORSHIP

WASTECH is committed to being a responsible member of communities where it operates, to supporting those in need which may include sponsoring various events, initiatives and organisations.

As bribes can be concealed in the form of charitable, donations or sponsorships, all CSR, donations and sponsorships shall be done in good faith and are not aimed to gain any business or other advantage in return, whether for WASTECH or self-enrich, that may be considered improper.

All CSR, donations and sponsorships must be pre-approved in writing by the Executive Director, and the respective director or employee must comply with the following:

  1. to ensure all CSR, donations and sponsorships are allowed by the local laws, and not made to improperly influence a business outcome or a person’s performance of duties or perceived to provide an improper advantage to WASTECH or yourself;
  2. to acquire all the necessary internal and external authorizations;
  3. to donate or work with well-established entities having an adequate organisational structure to guarantee proper administration of the funds;
  4. all donations and sponsorships must be transparent and properly recorded in the company’s books and records;
  5. shall not be used as a means to cover up an undue payment or bribery;
  6. must take proper processes and procedures, including without limitation proper background check or due diligence, to evaluate the legitimacy of an entity or a request for donations and sponsorships, before committing to or giving any funds. Any such processes and procedures taken shall be properly recorded and kept;
  7. must not be made to individuals or in cash; or be made at the request of a public official as an inducement to or reward for acting improperly;
  8. must not be made to parties engaging with WASTECH, during or after a contract negotiations or significant events; and
  9. all CSR, donations and sponsorships must be made in accordance with the approval limits in the limits of authority (as set forth by WASTECH’s internal policy).

As part of our ordinary course of business, WASTECH may provide for CSR, donation or sponsorship in cash or in kind to third parties for organising events or for a legitimate cause. Prior approval from the management and/or Head of Department is mandatory to do so. Employees of WASTECH in charge of such activity (for this purpose, the said employee is referred to as the “Requestor”) shall be required to fill in the Declaration and Acknowledgement Form [FORM-006-01-WG], including but not limited to, amount, quantities, usage and name of recipients. The Requestor’s department is required to keep a proper stock record of such forms for audit purposes and a copy shall be emailed to legal@wastech.com.my for reference.

In the event WASTECH receive CSR, donation or sponsorship in cash or in kind from third parties for organising events or for a legitimate cause, prior approval from the management and/or Head of Department is mandatory prior to receiving them. Employees of WASTECH in charge of such activity (for this purpose, the said employee is referred to as the “Recipient”) shall be required to fill in the Declaration and Acknowledgement Form [FORM-006-01-WG], including but not limited to, amount, quantities, usage and name of providers. The Recipient’s department is required to keep a proper stock record of such forms for audit purposes and a copy shall be emailed to legal@wastech.com.my for reference.

7. PROCUREMENT
7.1 Procurement Process

WASTECH is committed to applying the highest standard of ethics and integrity in all aspects of its procurement activities. Every director, employee and person acting on WASTECH’s behalf in procurement process shall comply with WASTECH’s various policies, in particular this Policy, the Code of Ethics and Conduct and other policies, guidelines and procedures related to this Policy.

In discharging the duties in procurement process, every director, employee, and person acting on WASTECH’s behalf should follow the guidance below:

  1. shall avoid any actual or potential conflict of interest. Every director, employee and person acting on WASTECH’s behalf who is involved in the procurement process shall make necessary declaration of interest (in the form and format in compliance with the Group’s prescribed requirements) regularly or when there is a change in circumstances which warrant a declaration, if applicable;
  2. shall not use personal influence, positions, or anything of value to improperly get the job from WASTECH or enter into any undertaking with third party in which his or her family members and friends have an interest directly or indirectly;
  3. avoid accepting or providing any entertainment, corporate hospitality, or gifts during critical period, such as tender process or contract negotiation;
  4. must ensure that all procurement activities are in line with the procurement policies and procedures of the company and this Policy. Ad hoc purchase request will not be processed unless with valid and exceptional reasons endorsed by the management and/or Head of Department;
  5. periodically monitor the Business Associate’s performance and business practices to ensure ongoing compliance with this Policy; and
  6. shall avoid dealing with any Business Associate known or reasonably suspected of corrupt practices or known or reasonably suspected to pay bribes. Exercise use good judgment and common sense in assessing the integrity and ethical business practices of the said Business Associates.
7.2 Due Diligence

Appropriate assessment shall be conducted by employees in the procurement process to understand the business and background of the prospective Business Associate prior to procurement process to ensure that they have acceptable standard of integrity in the conduct of their business, and they are free from any elements of bribery and corruption or conflict of interest.

The scope and extent of the due diligence required will vary depending upon the circumstances of each proposed transaction and it should commensurate with the risks of bribery and corruption and the amount involved in that transaction. Employees shall keep proper record of the risk assessment and due diligence performed.

7.3 Selection of Business Associates

Every director, employee and person acting on WASTECH’s behalf in procurement process must treat all of the prospective Business Associate fairly and equally. In deciding the procurement award, the decision must be based on approved objective criteria and not to be influenced by personal bias or favouritism.

Approval for procurement must be in accordance with the limit of authority and the guidelines for procurement as stated in WASTECH’s purchasing standard operating procedures. If the procurement is of substantial amount, a committee must be formed to make such decision collectively. In cases where awarding of the procurement to a particular Business Associate which are not solely based on the standard criteria, the reasons for such decision must be properly documented and kept.

Any director, employee and person acting on WASTECH’s behalf in procurement process must not enter into any business dealings with any third party reasonably suspected of engaging in bribery and corruption or any improper business practices unless those suspicions are investigated and resolved.

The Business Associate receiving the procurement award must be made aware of and agree to act in accordance with this Policy and the Code of Ethics and Conduct of WASTECH. Contracts with major contractors and suppliers should incorporate provisions where the WASTECH is given the right to terminate the contract in the event the Business Associate pay bribes or act in a manner which is inconsistent with this Policy.

7.4 Verification Process

Verification process shall be conducted to ensure all works, services, deliveries, and supplies are provided according to the approved procurement requests. Regular review or evaluation should be done on the quality and the pricing of work done, services or goods.

8. DEALINGS WITH PUBLIC OFFICIALS

A “Public Official” is defined as a person who works for or on behalf of a government, a government-controlled entity, a government related entity, a public body, or a public international organisation. This includes members of Parliament, State Assemblymen, judges, police officers, elected and appointed officers, employees, or representatives of national or federal government, state governments, local governments, government departments, government agencies, government owned companies, government-controlled companies, government linked companies, or public international organisations and officials of political parties and candidates for political offices.

Most countries in the world have made it an offence to bribe their own government officials, many have also made it an offence to bribe a foreign government official. As such, any director, employee, and person acting on WASTECH’s behalf must exercise extra caution and be more vigilant when dealing with Public Officials.

It is against this Policy to bribe any Public Officials anywhere in the world, whether or not such activities are considered illegal under the legislation in any country in which business is transacted.

You must obtain written approval from the Executive Director before offering any gift, entertainment or corporate hospitability to Public Officials or their family members. The gift, entertainment or corporate hospitality must not be frequent, absurd, excessive, and lavish, subject always to compliance with the local legislations and rules, and must commensurate with the official designation of the Public Official and not in his or her personal capacity.

All director, employee, and person acting on WASTECH’s behalf must act professionally and ethically and ensure that any offering of gift, entertainment or corporate hospitability to public officials or their family members is properly recorded in the relevant registry and such dealings are fully transparent, properly documented, and accounted for.

The director, employee, and person acting on WASTECH’s behalf must:

  1. never attempt to circumvent any laws or WASTECH’s policies; and
  2. never conceal, alter, destroy, or otherwise modify any documentation relating to gift, entertainment or corporate hospitality offered to any Public Officials or their family members.

For more information and guidance in relation to our gifts, entertainment, and corporate hospitability, kindly refer to Section 3 and Section 4 of this Policy.

9. POLITICAL CONTRIBUTION

WASTECH does not make or offer any political contributions, in-cash or in-kind, to any political parties, politicians, elected officials, or candidates for political office.

No director, employee, and person acting on WASTECH’s behalf shall make any political contribution on behalf of WASTECH or use WASTECH’s resources for the same purpose or use their position with WASTECH to try to influence other person to make political contributions.

10. MONEY LAUNDERING

“Money laundering” is defined as the process by which persons or groups try to conceal the proceeds of illegal activities or try to make the sources of their illegal funds look legitimate.

WASTECH objects to practices related to money laundering. In order to avoid violating anti-money laundering laws, employees are expected to conduct due diligence before entering into any business arrangement with any third party, if in doubt. Employees should conduct due diligence on the identity, background, and business of such third party and beneficial owners (if any) of such business arrangement, and determine the origin and destination of money, property, and services. Employees should keep proper records of the due diligence done, the business correspondence and documents relating to the business arrangement.

If there are any suspicious behaviours or activities, the employees should report it to its respective Head of Department, Compliance Department and/or Executive Director, who in return to onwards report it to the authorities via proper reporting channels.

11. PROCEDURES FOR PREVENTING BRIBERY AND CORRUPTION

This Policy lays out WASTECH’s general position, principles, procedures and guidelines in combating bribery and corruption. This Policy is not intended to be exhaustive and should be read together with WASTECH’s various policies and guidelines.

Each executive management, division or business unit is responsible for implementing a proportionate response, including but not limited to:

  1. applying appropriate due diligence procedures and taking a risk-based approach to ensure compliance with all applicable laws and regulations related to anti-bribery and corruption. All director, employee, and person acting on WASTECH’s behalf must exercise good judgment and due diligence with the paramount aim of avoiding all forms of bribery and corruption;
  2. risk assessment is to be conducted annually on operating companies to assess key compliance risks including the risks of bribery and corruption, and to determine the effectiveness of WASTECH’s corruption risk controls;
  3. training and communication of policies that is comprehensive and ongoing;
  4. established procedures to prevent and detect bribery and corruption. All operating companies may establish more stringent practices, and all employees must follow the standard operating procedures set;
  5. employees must ensure that all expense claims relating to entertainment, gifts or expenses incurred are submitted in accordance with the company’s expense policy and specifically record the reason for the expenditure;
  6. all accounts, invoices, and other similar documents and records relating to dealings with third parties should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments;
  7. employees have to ensure contractual arrangements with third parties in high-risk areas and other associated persons, shall include requirements for compliance with all applicable laws and regulations related to anti- bribery and corruption;
  8. procedures to monitor and review processes including the investigation, response and reporting of violations, incidents and other control weaknesses as well as implementing areas for improvement; and
  9. Registers of Gifts, Entertainment and Corporate Hospitality offered to directors, employees, and any person acting on WASTECH’s behalf (whether accepted or not) shall be kept locally based on the procedure noted in this Policy. This is to ensure transparency and local responsibility and oversight.
12. REPORTING OF VIOLATIONS OF THE POLICY

Any party (including external party) who has concern about possible violation of the Policy, is encouraged to whistle blow or report the concerns by completing the Whistleblowing Form in accordance with our Whistleblowing Policy contained in our official website or report it to whistleblowing@wastech.com.my.

No individual will be discriminated against or suffer any sort or manner of retaliation for raising genuine concerns or reporting in good faith on violations or suspected violations of this Policy. All reports will be treated confidentially.

13. SYSTEMATIC REVIEW, MONITORING AND ENFORCEMENT

The Compliance Department will monitor the effectiveness and review the implementation of this Policy in the respective countries. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. This Policy will be reviewed periodically by us and may be amended at any time as we deem fit. All director, employee and person acting on WASTECH’s behalf will be notified of any material revisions to this Policy.


This Policy is updated as at 28 November, 2023