In maintaining good governance, the Cagamas Group of Companies (the Company) is committed to conduct its businesses and operations with high ethical standards and integrity.
The Company adopts a zero-tolerance policy against all forms of Bribery and Corruption by its Directors, Management, employees and any individual/organisation acting for the Company and on its behalf and takes a strong stance against such acts.
The purpose of this policy statement is to:
- set out the Company’s responsibilities, and of those working or providing services for the Company (including service providers of the Company), in observing and upholding the Company’s position on Bribery and Corruption;
- provide information and guidance as to how the Company expects those working for the Company to conduct themselves and how to recognise and deal with Bribery and Corruption issues; and
- how to raise concerns with the Company including any breaches of this policy.
- any action which is considered as an offence of giving or receiving ‘gratification’ under the MACC Act.
- offering, giving, receiving or soliciting something of value in an attempt to illicitly influence the decisions or actions of a person in a position of trust within an organisation.
- any action which would be considered as an offence of giving or receiving ‘gratification’ under the MACC Act.
- may also include acts of extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering.
In recognition of this commitment, the Board of Directors and Management have implemented and enforced a comprehensive anti-bribery and anti-corruption program, which include an Anti-Bribery and Anti-Corruption Policy (ABC Policy):
- to prevent, deter, and monitor Bribery and Corruption in the Company’s business activities;
- provides guidance to the Board of Directors, Management, employees and individuals/organisation acting for the Company and on its behalf concerning how to deal with improper solicitation, Bribery and other corrupt activities and issues that may arise in the course of business;
- effectively manages the key Bribery and Corruption risks of the Company; and
- complies fully with the applicable laws and regulatory requirements on anti-bribery and anti-corruption.
The Board of Directors, Management, its employees and individuals/organisation acting for the Company and on its behalf are strictly prohibited from directly or indirectly soliciting, accepting or offering bribes in relation to Company’s businesses and operations.
The Company expects that individuals/organisation acting for the Company and on its behalf are aware of and commit themselves to the relevant parts of the Company’s ABC Policy and Whistleblowing Policy as well as adopt and agree to abide by ethical standard of business which are also set out in the Vendor Code of Conduct when performing such work or services for or on behalf of the Company.
The Company shall conduct due diligence to assess the integrity of prospective individuals/organisation acting for the Company and on its behalf prior to entering into any formalised relationships to avoid dealing with any such individuals known or reasonably suspected of corrupt practices and shall not enter into any business dealings unless those suspicions are investigated and resolved.
Where an individual/organisation acting for the Company and on its behalf, sub-contracts with another third party to render services under the main/master contract with the Company, sub-contracting provisions should require the said individua/organisation to procure its subcontractors to abide by the Company’s Vendor Code of Conduct, ABC Policy and the Whistleblowing Policy.
For individuals/organisations acting for the Company and on its behalf, who breached any of the Vendor Code of Conduct, ABC Policy, Whistleblowing Policy and relevant related regulatory requirements, may lead to penalties including termination of contract by the Company. Further legal action may also be taken if the Company’s interests have been harmed as a result of non-compliance by the said individuals and organisations.
The Company provides an avenue for stakeholders to disclose any improper conduct which include Bribery through a secured whistleblowing channel. All genuine concerns of any alleged or suspected Bribery, Corruption, criminal activities or serious breach of the Company’s Code of Conduct and Ethics can be raised through Whistleblowing channels which are also available on the Company’s website.
Any person who makes a report or disclosure about any actual or perceived Bribery or Corruption in good faith, belief, without malicious intent, that a breach or violation as aforesaid may have occurred or may occur, will be accorded protection of confidentiality. Employees who whistleblow internally will be also be protected against detrimental action for having made the disclosure, to the extent reasonably practicable, regardless of the outcome of any investigation.