Anti-Bribery and Anti-Corruption Policy

Introduction

Malaysia Healthcare Travel Council (hereinafter referred to as “MHTC” or the “Company”) Anti-Bribery and Anti-Corruption Policy (hereinafter referred to as the “Policy”) is a reference document of MHTC on policy matters relating to the prevention of bribery and corruption. It is not intended to be one-size-fits-all that will provide solutions to all issues.

The Board of Directors of MHTC and the Management of MHTC recognise its role to promote culture of integrity and to ensure that business activities and operations shall always be conducted in an honest and ethical manner.

Commitment

MHTC has a zero-tolerance approach towards all forms of bribery and corruption and is committed to act with the highest level of integrity in its business dealings and relationships in all jurisdictions that it operates.

The Board of Directors of MHTC and the Management of MHTC are committed to implementing and enforcing effective actions to combat bribery and corruption which are punishable offences in accordance with the anti-corruption laws.

MHTC has developed a framework which includes the policies, procedures, risk assessments, due diligence on third parties and associated persons, and employee training programme.

Compliance with the Policy constitutes conditions of employment and further constitutes conditions of providing services by Business Associate to MHTC. Each such person agrees to be bound by the provisions of this Policy as mutually agreed by the Business Associates in MHTC’s standard contracts and/or agreements

Gifts, Hospitality and Entertainment

It is MHTC’s policy that no Employee or his immediate family members shall accept any form of gifts (except for Corporate Gifts) or favours from Business Associates, if it could be perceived as intended to, or likely to, influence him in the fair, impartial and efficient discharge of their duties. Gifts should only be offered to and received in connection with a customary business or cultural occasion (cash, loans, kickbacks or the equivalent advantages are absolutely prohibited). For avoidance of doubt, Gifts must not exceed RM500.00 and in any event, must not occur more than 3 times a year with the same person or organization.

Employees of MHTC shall not accept any gratuitous entertainment from any of the Business Associates.

In the event Employees of MHTC receive any gifts from clients, customers, business partners, or any other party having business dealing with the Company, the Employees are required to declare the same to their respective Head of Department and refer to the steps and procedures set out in the MHTC’s Employee Code of Conduct to avoid ambiguity, allegations and conflict of interest.

Facilitation Payments and Kickbacks

MHTC does not make and will not accept facilitation payments or “kickbacks” of any kind by any of its Employees and Business Associates. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official.

Kickbacks are typically payments made in return for a business favour or advantage. All MHTC’s Employees and Business Associates must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by MHTC.

Donations and Sponsorships

No donation shall be made or offered by the Employees of MHTC.

Sponsorships are permitted in carrying out the business activities of the Company and in accordance with the Limits of Authority. However, the Company prohibits the giving and receiving of donations and sponsorships to influence business decisions.

Conflicts of Interest

Conflicts of interest arise in situations where there is a personal interest that could be considered to have potential interference with objectivity in performing duties or exercising judgment on behalf of MHTC. All Employees should avoid situations in which personal interest could conflict with their professional obligations or duties. Employees must not use their position, official working hours, Company’s resources and assets, or information available to them for personal gain or to the Company’s disadvantage.

In situations where a conflict does occur, Employees shall declare such matter in any form or format as they please to the respective Heads of Department as per the Employee Code of Conduct.

Record-Keeping

MHTC must keep financial records (together with relevant supporting documents) and have appropriate internal controls in place, which will evidence the business reason for making or accepting payments or gifts to or from third parties. The financial records must be retained for at least seven years and produced on request by the custodian of the process.

Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties comply with all policies and guidelines and specifically record the reasons for the expenditure.

All accounts, invoices, other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, must be prepared and maintained with accuracy and completeness.

No accounts must be kept “off-book” or considered “off-record” to facilitate or conceal improper payments.

How to Raise Concern

All Employees or Business Associates are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage if he believes or suspects that a conflict with this Policy has occurred or might occur in the future.

Training and Communication

Training on this Policy forms part of the induction process for all MHTC’s new and existing Employees.

Monitoring and Review

Heads of Departments, Top Level Management and Audit Committee must monitor the effectiveness and review the implementation of this Policy regularly considering its suitability, adequacy and effectiveness. Any improvements identified shall be made as soon as possible.

Internal control systems and procedures shall be subjected to regular reviews or audits to provide assurance that they are effective in countering bribery and corruption.

All MHTC’s Employees are responsible for the success of this Policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Sanctions for Non-Compliance

Non-compliance as identified by the audit and any risk areas identified through this and other means should be reported to the Top-Level Management and/or Audit Committee in a timely manner in accordance with the level of risk identified.

MHTC regards bribery and acts of corruption as serious matters and will apply penalties in the event of non-compliance to this Policy. For Employees, non-compliance may lead to disciplinary action, up to and including termination of employment.

For Business Associates, non-compliance may lead to penalties including termination of contract. Further legal action may also be taken in the event that MHTC’s interests have been harmed or damaged as a result of non-compliance by individuals and organisations in accordance with provision of the agreements.

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