Anti-Bribery & Anti-Corruption (ABAC) Policy

1. Purpose

Bayarcash is committed to conduct business ethically, with integrity, and in compliance with all applicable anti-bribery and anti-corruption laws. This policy is designed to:

• Establish clear standards and expectations in preventing bribery and corruption.
• Ensure compliance with the Malaysian Anti-Corruption Commission (MACC) Act 2009, particularly Section 17A on corporate liability.
• Protect Bayarcash, its employees, and business partners from legal, financial, and reputational risks.

2. Scope

This policy applies to:

• All Bayarcash directors, management, and employees.
• Contractors, consultants, interns, and trainees engaged by Bayarcash.
• Third parties acting on behalf of Bayarcash, including partners, vendors, merchants, and service providers.

3. Policy Statement

• Bayarcash adopts a zero-tolerance approach towards bribery and corruption.
• No employee, officer, or business partner shall offer, give, solicit, or accept any form of bribe, gratification, or improper advantage, either directly or indirectly.
• Compliance with this policy is mandatory and non-negotiable.

4. Key Definitions (as per MACC Act 2009)

• Bribery / Gratification: Includes money, gifts, property, services, employment, contracts, favours, or anything of value intended to induce or reward improper performance.
• Corruption: Abuse of entrusted power for personal or organizational gain.
• Facilitation Payments: Small, unofficial payments made to secure or expedite routine actions - strictly prohibited under this policy.

5. Prohibited Conduct

Employees and business partners must not:

• Offer, give, request, or accept bribes or improper advantages.
• Provide or accept facilitation payments, kickbacks, or secret commissions.
• Use third parties (agents, consultants, vendors) to circumvent this policy.
• Offer gifts, hospitality, entertainment, or donations with the intention to improperly influence business decisions.
• Conceal, falsify, or misrepresent transactions or records.

6. Gifts, Hospitality & Entertainment

• Modest, occasional, and transparent gifts or hospitality may be acceptable if they are:
  • Reasonable and proportionate.
  • Not intended to influence a business decision or gain improper advantage.
  • In line with Bayarcash’s Gifts & Hospitality Guidelines.
• All gifts and hospitality must be declared and recorded in the Gifts & Hospitality Register.

7. Charitable Donations & Sponsorships

• Donations and sponsorships must not be used as a channel for bribery or corruption.
• All contributions must be transparent, properly documented, and approved by management.

8. Political Contributions

• Bayarcash does not make political donations or contributions.
• Employees must not use company funds or resources for political purposes.

9. Roles & Responsibilities

Bayarcash assigns clear responsibilities to ensure effective implementation of its Anti-Bribery and Anti-Corruption (ABAC) policy across all levels of the organisation.

10. Reporting & Whistleblowing

• Employees and stakeholders are encouraged to report concerns of bribery, corruption, or policy violations through Bayarcash’s Whistleblowing Policy.
• Reports will be treated confidentially and whistleblowers will be protected from retaliation.

11. Training & Awareness

• All employees will undergo regular ABAC training and awareness programs.
• Business partners and service providers will be informed of Bayarcash’s ABAC requirements.

12. Record Keeping

• Accurate and transparent records must be maintained for all transactions, payments, and business dealings.
• No undisclosed or unrecorded accounts are permitted.

13. Disciplinary Action & Consequences

• Any violation of this policy may result in disciplinary action, including termination of employment or contracts.
• Breaches may also lead to civil or criminal liability under the MACC Act 2009.

14. Review of Policy

This policy will be reviewed annually or as required by changes in law, regulations, or business practices.