Anti-Bribery and Corruption Policy
**Effective Date: 01 September 2024**
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**1. Policy Statement**
Project Volcan is committed to conducting business with the highest ethical standards. We maintain a strict zero-tolerance approach towards bribery and corruption across all levels of our operations.
**2. Scope**
This policy applies to all directors, officers, employees, agents, contractors, and any third parties acting on behalf of Project Volcan. It covers dealings with both the public and private sectors, in Malaysia and globally.
**3. Prohibited Conduct**
Bribery, kickbacks, or improper gratifications of any kind are strictly forbidden. This includes giving, receiving, or offering anything of value to improperly influence business decisions.
**4. Gifts, Hospitality, and Entertainment**
Gifts and hospitality must be appropriate, modest, and not intended to influence decision-making. Any such activity must be transparent, and employees should seek approval from supervisors before offering or accepting gifts.
**5. Facilitation Payments**
Project Volcan does not allow facilitation payments (unofficial payments made to expedite government services). Any such demand must be reported immediately.
**6. Donations and Sponsorships**
Donations, sponsorships, and charitable contributions must be made in good faith and without any expectation of commercial gain. Political donations are strictly prohibited.
**7. Due Diligence and Record Keeping**
All dealings with third parties must involve proper due diligence, ensuring that they uphold similar anti-corruption standards. Accurate records of transactions, expenses, and gifts must be maintained.
**8. Compliance**
All employees are responsible for understanding and adhering to this policy, as well as local anti-bribery laws (e.g., the Malaysian Anti-Corruption Commission Act 2009). Training and periodic reviews of this policy will ensure ongoing compliance.
**9. Reporting and Enforcement**
Employees and third parties are encouraged to report any suspicions of bribery or corruption through the designated whistleblowing channels, with protection from retaliation.
**10. Consequences of Breach**
Any breach of this policy may result in severe disciplinary action, including termination of employment or contract, and may also result in criminal prosecution.
**11. Policy Review**
This policy will be reviewed periodically to ensure its continued effectiveness and compliance with applicable laws.
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