ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Consultface Sdn Bhd (FACE) is committed to conduct its business in an honourable, ethical and professional manner. FACE has adopted zero tolerance approach to non- compliance/ breaches with regulatory obligations and laws.

This Anti-Bribery and Anti-Corruption (“ABAC”) Statement represents FACE’s commitment in zero tolerance to all form of bribery and corruption.

The standards of FACE ABAC framework and measures are guided by the T.R.U.S.T principles of the Malaysia Prime Minister’s Office – Guidelines on Adequate Procedures:

• Top Level Commitment

• Risk Assessment

• Undertake control measures

• Systematic review, monitoring and enforcement

• Training and Communication

 ABAC STANDARDS

FACE strictly prohibits any act of bribery and corruption regardless of its form, and requires all its employees to observe and apply FACE’s core ethical values in their day-to-day operations and business affairs to protect FACE’s reputation.

The following are the key ABAC standards that must be adhered to:

1.  Giving and Accepting of Gifts & Hospitality

FACE prohibits employees from offering, soliciting or receiving any gifts or hospitality in any form, to or from current or potential clients, vendors, and contractors, either directly or indirectly which may influence the employee’s judgment in a decision-making process or put the employee in a position of conflict.

2.  Dealing with Government Officials

Any giving or receiving directly or indirectly of, kickbacks or gratuities to/ from government officials is not allowed. Due care and diligence must be exercised at all times when dealing with government officials or related associated persons.

3.  Facilitation Payments

FACE prohibits any form of offering, giving or accepting any form (either in cash or anything of value) of improper payments such as bribes or kickbacks in exchange for business favours, information and favourable treatment.

4.  Donations and sponsorships

FACE does not allow its business to be used as a channel for money laundering, terrorism financing or other criminal activities.

5.  Recruitment of employees

FACE recognizes the value of integrity in its personnel and business associates. The Company’s recruitment, training, performance evaluation, remuneration, recognition and promotion for all FACE personnel, including management, shall be designed and regularly updated to recognize integrity.

6. Third-Party/Business Associates Relationship

All business associates (including external providers such as consultants, advisors, and agents) acting on behalf of FACE are required to comply with this Policy, the FACE’s Code of Business Ethics, and all other policies as it relates to them. All employees are required to exercise due care and due diligence at all times when dealing with third- parties/ business associates and ensure their affairs do not involve any form of corrupt practices, perceived or actual.

7. Conflict of interest

All employees must ensure that personal and business affairs do not conflict with or appear to be conflicting with FACE’s interests. FACE carries out regular risk assessments, monitoring, testing training and communication of its ABAC programme. FACE also maintains clear whistleblowing policies and processes, to ensure that individuals can confidentially report concerns, without fear of retribution, confident that they will be investigated and remediated appropriately.