Anti-Bribery and Corruption Policy

TAPiO Management Advisory Sdn. Bhd. is committed to conducting business with integrity, transparency and professional independence. Bribery and corruption are incompatible with those commitments and are prohibited in every market in which we operate.

We do not offer, promise, give, request, agree to receive or accept a bribe, kickback or improper advantage. We do not authorise another person to do so on our behalf.

This Policy applies to TAPiO’s directors, officers, employees and interns. It also applies, to the extent relevant to their work for TAPiO, to consultants, contractors, agents, introducers, representatives and other persons performing services for or on behalf of TAPiO (collectively, Associated Persons).

Business partners are expected to act consistently with applicable anti-bribery law and the principles relevant to their relationship with TAPiO.

This Policy is designed to support compliance with the Malaysian Anti-Corruption Commission Act 2009, including the corporate-liability framework under section 17A, and other anti-bribery laws that may apply to a particular transaction, person or engagement.

Our anti-bribery controls are intended to be proportionate to TAPiO’s size, activities and risk profile and are informed by Malaysia’s adequate-procedures principles: Top-Level Commitment, Risk Assessment, Undertake Control Measures, Systematic Review, Monitoring and Enforcement, and Training and Communication (T.R.U.S.T.).

This Policy does not state or imply that TAPiO holds ISO 37001 or any other anti-bribery certification unless TAPiO expressly confirms such certification separately.

No person acting for or on behalf of TAPiO may directly or indirectly:

• offer, promise, give, authorise, request or accept money, gifts, hospitality, employment, services, discounts, commissions, favours or anything else of value in order to improperly influence a decision or secure an improper advantage;
• pay or receive a kickback, secret commission or undisclosed personal benefit;
• use an agent, consultant, intermediary, family member, supplier, client or other third party to do something that TAPiO could not properly do itself;
• make a payment knowing or reasonably suspecting that all or part of it will be passed to another person as a bribe;
• conceal an improper payment through false invoices, inflated fees, sham services, miscellaneous expenses or inaccurate accounting;
• retaliate against a person who raises a genuine concern or refuses to participate in improper conduct; or
• ignore warning signs because a transaction is commercially attractive or time-sensitive.

TAPiO regularly engages with public authorities and institutional stakeholders as part of legitimate advisory, market-entry and government-relations work. Such access and relationships must never be used to obtain an improper advantage.

Interactions with public officials must have a legitimate business purpose, be professional, transparent and lawful, and avoid any benefit that could reasonably be perceived as intended to influence an official act. Particular care is required during tenders, licensing, approvals, inspections, grants, incentives, procurement, regulatory matters and other decision-making processes.

The term public official is interpreted broadly and includes persons holding legislative, administrative, judicial, public-agency, state-owned enterprise or similar public functions, as well as candidates and political-party officials where relevant under applicable law.

TAPiO prohibits facilitation or “grease” payments made to obtain or speed up a routine action to which a person is already entitled, unless a payment is an official, published fee lawfully payable to the relevant authority.

If a payment is demanded under an immediate and credible threat to health, safety or liberty, personal safety comes first. Any payment made under such duress must be reported promptly and recorded accurately so that appropriate follow-up can occur.

Reasonable business courtesies can support legitimate professional relationships, but they must never be used to influence a decision improperly.

Gifts, meals, hospitality, travel or accommodation offered or accepted in connection with TAPiO business must be:

• lawful, bona fide and connected to a legitimate business purpose;
• reasonable and proportionate in value and frequency;
• transparent and capable of being recorded accurately;
• not cash or a cash equivalent, except authorised reimbursement of legitimate documented expenses;
• not requested by the recipient as a condition for performing a duty;
• not offered or accepted when it could reasonably compromise, or appear to compromise, an ongoing tender, procurement, approval or other decision; and
• subject to any client, public-sector or internal approval rules applicable to the recipient.

Where there is doubt, the courtesy is declined or referred for management approval before it is offered or accepted. Material disclosures and approvals are recorded in writing.

Charitable donations and sponsorships must be genuine, documented and not used as a substitute for an improper payment. The recipient, timing and circumstances inform the level of review, with additional checks and management review where the corruption or integrity risk warrants them.

Any political contribution made in TAPiO’s name or with TAPiO funds requires prior approval by the Board or other authorised governing authority, must be lawful and transparent, and must never be made to obtain or retain business or another improper advantage. Personal political activity must be clearly separated from TAPiO and must not use company resources without authorisation.

Intermediaries, representatives and other parties acting on TAPiO’s behalf are reviewed in proportion to the nature and risk of the relationship. Relevant considerations include their identity, proposed role, stakeholder relationships, commercial terms, potential conflicts and integrity concerns. Higher-risk relationships receive additional checks and management review where appropriate.

Fees, commissions and referral arrangements must reflect legitimate documented services, be commercially reasonable and be paid transparently to the contracting party. Unusual payment requests or unclear services require further review and may lead to an engagement being declined.

Anti-bribery, compliance and termination provisions are included or strengthened where warranted by the relationship.

Supplier selection, client recommendations and other business decisions must be based on legitimate business criteria. Personal relationships, financial interests, gifts or undisclosed referral benefits must not influence the decision. Conflicts are handled under the Conflict of Interest Policy.

Transactions must be recorded completely and accurately. False descriptions, unrecorded funds, undisclosed accounts, fabricated invoices, disguised benefits and off-book payments are prohibited.

Our record-keeping standards require expense claims to identify the legitimate business purpose and relevant participants where appropriate. Supporting records must be retained in accordance with applicable financial, tax and record-retention requirements.

TAPiO applies a risk-based approach to corruption prevention. Checks and management oversight reflect the engagement, relevant markets, government interactions, intermediaries, payment arrangements and any warning signs. Higher-risk matters receive closer review and appropriate safeguards.

Anyone covered by this Policy who becomes aware of suspected bribery, corruption, falsified records, a suspicious payment request or another serious concern is expected to report it promptly through management or the mechanism described in our Speak-Up & Whistleblowing Policy.

No employee or Associated Person is expected to proceed with a transaction merely because refusing or delaying it may cause commercial loss.

TAPiO will assess credible allegations fairly and as confidentially as reasonably possible. Personnel are expected to cooperate with legitimate investigations and preserve relevant records.

Retaliation against a person who raises a concern in good faith or refuses to participate in conduct reasonably believed to violate this Policy is prohibited.

These standards are communicated through induction, relevant briefings and ongoing guidance. External representatives receive the requirements applicable to their engagement through engagement terms and direct communication.

TAPiO reviews relevant transactions and records where appropriate and takes proportionate action on identified concerns. Breaches may lead to disciplinary or contractual action, recovery action or referral to competent authorities, with fair treatment and regard to applicable law.

Top management is responsible for setting the tone of integrity and ensuring proportionate resources and controls. Managers are responsible for applying this Policy within their work. Every person covered by it is responsible for understanding the standards relevant to their role, seeking guidance when uncertain and reporting concerns promptly.

Questions about this Policy may be sent to inquiry@tapio.my. For suspected misconduct, our Speak-Up and Whistleblowing Policy explains the confidential reporting options.