Anti-Bribery and Corruption Policy

AmGeneral has zero tolerance policy to non-compliance/ breaches with regulatory obligations and laws. And is committed to conduct its business in an honest, ethical and professional manner.

This Anti-Bribery and Corruption (“ABC”) Statement represents AmGeneral’s commitment in zero tolerance to bribery and corruption.   

The standards of AmGeneral ABC framework and measures are guided by the T.R.U.S.T principles of the Malaysia Prime Minister’s Office – Guidelines on Adequate Procedures:

i. Top Level Commitment 

ii. Risk Assessment

iii. Undertake control measures

iv. Systematic review, monitoring and enforcement 

v. Training and Communication
 

ABC STANDARDS
As enshrined in AmGeneral’s Code of Conduct and Code of Ethics (compliant, responsible, ethical, accurate, trustworthy, equitable), AmGeneral strictly prohibits any act of bribery and corruption regardless of its form, and requires all its employees to observe and apply AmGeneral’s core ethical values in their day-to-day operations and business affairs to protect AmGeneral’s reputation.

The following are the key ABC standards that must be adhered to:

1. Giving and Accepting of Gifts & Hospitality
AmGeneral prohibits employees from offering, soliciting or receiving any gifts or hospitality in any form, to or from current or potential customers, vendors, agents and business partners, either directly or indirectly which may influence the employee’s judgment in a decision-making process or put the employee in a position of conflict.

2. Dealing with Government Officials
Any giving or receiving directly or indirectly of, kickbacks or gratuities to/ from government officials is not allowed. Due care and diligence must be exercised at all times when dealing with government officials or related associated persons.

3. Facilitation Payments
AmGeneral prohibits any form of offering, giving or accepting any form (either in cash or anything of value) of improper payments such as bribes or kickbacks in exchange for business favours, information and favourable treatment.

4. Donations and sponsorships
AmGeneral does not allow its business to be used as a channel for money laundering, terrorism financing or other criminal activities. 

5. Recruitment of employees
AmGeneral prohibits any form of employment opportunities, whether permanent or temporary in nature, that is used as an inducement to obtain or retain an advantage in business.

6. Third-Party/ Business Associates Relationship
All employees are required to exercise due care and due diligence at all times when dealing with third-parties/ business associates and ensure their affairs do not involve any form of corrupt practices, perceived or actual.

AmGeneral prohibits the following practices in dealing with procurement activities:

i. Collusive practice – arrangement with two or more parties designed to achieve improper purpose or improper influence to the other party;

ii. Corrupt practice – offering, giving, receiving, soliciting, directly or indirectly anything of value to influence improperly the action of another party;

iii. Fraudulent practice – any act or omission including misrepresentation that knowingly or recklessly misleads or attempts to mislead a party to obtain a financial benefit or to avoid obligation;

iv. Theft – misappropriation of property belonging to another party;

v. Applying threats – any act by employees to create fear and for example by citing a senior management name or any persons of a higher authority within AmGeneral or any other acts with the intent to prevent another employee from performing his duties or induce an employee to act against to the standards and principles set by AmGeneral.

7. Conflict of interest
All employees must ensure that personal and business affairs do not conflict with or appear to be conflicting with AmGeneral’s interests.

AmGeneral carries out regular risk assessments, monitoring, testing training and communication of its ABC programme.

AmGeneral also maintains clear whistleblowing policies and processes, to ensure that individuals can confidentially report concerns, without fear of retribution, confident that they will be investigated and remediated appropriately. 

Click here to refer to AmGeneral’s Whistleblower Protection policy.