Anti-Bribery & Corruption Policy

Effective Date: 18 Nov 2023

1. Introduction

This Anti-Bribery and Corruption Policy (the “Policy”) is established in accordance with the Malaysian Anti-Corruption Commission Act 2009 (MACCA) and is designed to comply with all applicable anti-bribery and anti-corruption laws and regulations. Macromac is committed to conducting its business ethically and in compliance with all laws and regulations.

2. Scope

This Policy applies to all employees, officers, directors, agents, consultants, contractors, and any other individuals or entities acting for or on behalf of Macromac, in all countries where we operate.

3. Policy Statement

Macromac strictly prohibits bribery and corruption in any form. This includes, but is not limited to, offering, promising, giving, accepting, or soliciting anything of value either directly or indirectly in exchange for an improper advantage.

4. Gifts and Hospitality

Gifts and hospitality may only be offered or accepted in compliance with applicable laws and where they do not improperly influence, or appear to influence, decision making. All gifts and hospitality must be recorded in the company’s Gift and Hospitality Register.

5. Political and Charitable Contributions

Macromac prohibits political contributions that are intended to influence business decisions. Charitable contributions must be legal and ethical under local laws and practices and must be approved in advance by the company’s legal department.

6. Record Keeping

Accurate and complete records of all business transactions must be maintained. This includes records related to financial transactions and gifts, hospitality, political and charitable contributions.

7. Reporting and Whistleblowing

Employees and associates are encouraged to report any suspected or actual instances of bribery, corruption, or violation of this Policy. Macromac provides a secure and confidential reporting channel and ensures that no individual will suffer retaliation for reporting in good faith.

8. Compliance and Enforcement

Compliance with this Policy is mandatory. Violations will result in disciplinary action, up to and including termination of employment or contracts.

9. Training and Communication

Macromac will provide training on this Policy to all employees and relevant external parties. This Policy will be communicated to all employees and made available to the public on the Macromac website.

10. Policy Review and Updates

This Policy will be reviewed regularly and updated as necessary to ensure compliance with applicable laws and best practices.