ANTI-BRIBERY AND CORRUPTION POLICY
INTRODUCTION
This anti-bribery and corruption (ABC) policy is to prevent the occurrence of corruption and bribery practice in relation to the business of the Group. Newfields Group conducts its business in a legal and ethical manner.
OBJECTIVE
This policy sets out to provide information and guidance on the overall position bribery and corruption in all its forms.
SCOPE OF POLICY
This policy applies to all employees (whether temporary, fixed term, or permanent), and directors of Newfields Group including its subsidiaries and branches. It is also applicable to contractors, sub-contractors, consultants, agents, representatives, services providers or any other person or persons associated with Newfields Group (including third parties) when performing work or services, for or on behalf of Newfields Group.
All employees have to read and understand the Policy, failure which may result in disciplinary action, including termination of employment.
CONFLICTS OF INTEREST
All employees or directors must safeguard the interest of the Company and should avoid situations in which personal interest could conflict with their professional obligations or duties.
A conflict of interest can arise in many kinds of circumstances, such as involve a direct or indirect financial interest in a customer or supplier. Employees cannot use information or business opportunities they gain through their employment with the Company to benefit themself, their friends or their family personally; 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.
Employees are not allowed to engage in any private work, trade or business in or outside the Company, which may conflict with the company’s interest.
Any employee who is found engaging in any private work of business shall be liable to be terminated from service without any compensation whatsoever and the Company reserves the right to sue the employee for liquidated damages where applicable.
In situation where a conflict does occur, employees are required to declare the matter to his/her immediate superior and HR Department.
COMMON FORMS OF BRIBERY AND CORRUPTION
Gifts, Entertainment, Hospitality and Travel
Gifts and Hospitality
The Company accepts normal and appropriate business hospitality, for examples:
- Corporate gifts offered in business situations to all participants and attendees on work-related conferences, seminars and/or business events
- Gifts given in gratitude for hosting business events, conferences and/or seminars
- Meals for business purposes
- Refreshments or meals during meetings
- Discounts or other preferential treatments if it is available to all employees
All employees and directors are prohibited from receiving or asking gifts from external parties in the form of:
- Cash or cash equivalents, including gift cards or certificates, loans, commissions, coupons, discounts or any other related forms
- Offered or made during any stage of a procurement/sales process or intended to influence or reward the recipient
Only authorised personnel are allowed to purchase gifts to external parties, he/she must obtain written approval from the Group Managing Director before offering or providing gifts, regardless of the gift’s value.
Entertainment and Travel
Entertainment activities may include dining at restaurants, bistros, fast food restaurants, social activity such as karaoke and clubs. Prior approval must be obtained from the Management for any activities other than those mentioned above. The details of the business purpose of the expenses and person entertained must be clearly indicated for approval.
Employees are allowed to claim for the travelling expenses incurred for business purposes only. In the event if travel and accommodation provided to third parties, it should be at reasonable cost, the payment directly to third party vendors (e.g. hotels, travel agents) and not to the traveller whenever possible and not be made in cash, must be supported by receipt (when direct payments to vendors are not possible), provided only for person with a legitimate business relationship to the Company and not to friends or family of such persons.
Donations and Sponsorship
Donations, sponsorship and any charitable contributions by Newfields Group, whether in-kind services, knowledge, time or direct financial contributions must be reviewed and approved by the Chairman or Group Managing Director. The records of all contributions shall be kept by the Finance and HR Department.
Facilitation Payments
Facilitation payments is prohibited, the Company does not accept and will not make any form of facilitation payments of any nature.
RECORD KEEPING
All the records of gift purchase, donation and payment information must be maintained with accuracy and completeness.
REPORTING IMPROPER CONDUCT
Any employee can report the event with his/her identity or anonymously to his/her immediate superior/ the next highest or another level of management, including to an appropriate Board member / HR department. It can be reported verbally or in writing. All report will be treated as confidentially.
Contact Details:
Attention : Chairman / Group Managing Director of Newfields Group
Newfields Group of Companies
Suite 17.1, Level 17,
76, Menara Weld, Jalan Raja Chulan,
50200 Kula Lumpur.
DISCIPLINE FOR NON-COMPLIANCE
Any employee or director who is concerned in the affairs of the Company breaches the anti-bribery and corruption procedures and policy may lead to disciplinary action, including termination of employment or directorship.
TRAINING AND AWARENESS
The Company will conduct an awareness program for all employees and director regarding anti-bribery and corruption, integrity and ethic on a regular basis. Training will be provided to every new comer to the Company.
REVIEW OF THE POLICY
The Company will review this policy from time to time and to ensure that it continues to remain relevant and appropriate.