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GROUP ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1.0 INTRODUCTION

LLC Berhad (“LLC”) and its subsidiaries (“Group”) are committed to conduct its business in a fair, open, honest, legal and ethical manner. The Group practices high ethical standards of professionalism and with integrity in everything that we do.

This Anti-Bribery and Anti-Corruption Policy (“ABAAC Policy”) represents the Group commitment in zero tolerance to all forms of bribery and corruption. As such, it provides a clear policy of the conduct which is expected of the Group’s personnel.

The standard of the Group ABAAC Policy are guided by the T.R.U.S.T principles of the Malaysia Anti-Corruption (MACC) Act 2009 (including its subsequent amendments) as follows:-

T – Top Level Commitment

R – Risk Assessment

U – Undertake Control Measures

S – Systematic Review, Monitoring And Enforcement

T – Training And Communication

2.0 OBJECTIVE

The Board of Directors of the Group is committed to comply with the MACC Act 2009. Thus, this ABAAC Policy sets out the Group’s overall position to strictly prohibit any acts of bribery and corruption, and requires all its personnel to observe and apply the Group 8 core value of PRACTICE (Passion, Results oriented, Accountability, Change responsiveness, Teamwork, Integrity & loyalty, Creative & innovative, Equity) in their day-to-day operations and business affairs for the interest and reputation of the Group.

This ABAAC Policy is to provide guidance and ensure our personnel and business associates are aware of their obligations to prevent any acts of corruption, conflicts of interest or similar unethical acts, as well as to understand their roles and responsibilities.

3.0 SCOPE AND COVERAGE

This ABAAC Policy applies to all directors (both executive and non-executive), personnel of the Group (including permanent, fixed-term contract, part-time and interns), partners, business associates of the Group and any third party (person or entity) with whom the Group has, or plans to establish, some form of business relationship and include those who performs services for or on behalf of the Group.

This ABAAC Policy is specifically sets out with the minimum standards to which all directors and personnel of the Group are bound to observe in the performance of their duties at all times.

Each personnel has a duty to read and understand this ABAAC Policy. Non-compliance of any of this ABAAC Policy’s provisions may lead to stern disciplinary action, up to and including dismissal from employment. Further legal action may also be taken in the event that the Group’s interests has been harmed as a result of the said non-compliance.

4.0 DEFINITIONS

For the purpose of this ABAAC Policy:

a. Bribery means the act of offering, giving, promising, accepting ‘gratification’ or soliciting something of value in exchange for some kind of influence or action in return which is illegal, unethical or breach of trust.

b. Corruption is the abuse of entrusted power for personal gain. It is the act of giving or receiving of any gratification in the form of monetary or in-kind of high monetary value or non-monetary value whether for the benefit of that person or another person with the intent to obtain or retain business for the commercial organization; or to obtain or retain an advantage in the conduct of business for the commercial organization.

c. Gratification refers to anything of monetary and non-monetary value or benefit which includes but is not limited to money, donation, gift, loan, fee, reward, financial benefit, valuable security, property or interest in property, employment, appointment, forbearance, offer, undertaking, rebate, discount, services employment or contract of employment or services and agreement to give employment or render services in any capacity.

d. Subsidiary refers to company/ companies in which LLC Berhad has a controlling interest.

5.0 ANTI-BRIBERY AND ANTI-CORRUPTION STATEMENT

This ABAAC Policy is based on legal obligation, non-compliance of this policy not only severely damage the reputation of the Group and its personnel but they are also subject to penalties, including fines and imprisonment. Therefore, the Group and business associates shall not, whether directly or indirectly, offer, give, receive or solicit any item of value, to illicitly influence the decisions or actions of a person in a position of trust within an organization, either for the intended benefit of the Group or the person involved in the transaction.

This statement applies equally to the Group’s business dealings with commercial (private sector) and Government (public sector) entities, and includes interactions with their directors, employees, agents, and other appointed representatives at all levels such as government officials, politicians and public bodies.

The Group conducts due diligence on personnel who holds or may be holding a vulnerable position to bribery including projects and major business activities involving donations and sponsorship, in particular where there is significant exposure to bribery and corruption risk, in line with this ABAAC Policy.

The Group encourages personnel and business associates to report any suspected, attempted or actual bribery and corruption cases, and prohibits retaliation against those making reports in good faith. No personnel will suffer demotion, penalty, or any adverse consequences for refusing to pay or receive bribes or other illicit behavior, even if such refusal may result in the Group losing business or a delay in business operations.

6.0 PRINCIPLES ON ANTI-BRIBERY AND ANTI-CORRUPTION

6.1 CONFLICT OF INTEREST

All personnel must ensure that personal interests and business affairs or other activities outside the Group whether it benefits themselves or their closely related person(s), i.e. relatives or close associates, do not conflict or may appear to be compete or conflict with the interests of the Group.

All personnel shall declare their conflict of interest as soon as they are aware to their relevant heads of departments businesses.

6.2 GIFTS AND HOSPITALITY

As a general normal business hospitality principle, personnel may accept or offer gifts and hospitality as long as it is infrequent, reasonable, and modest in value where there is no risk of improper influence on a decision and is a bona fide corporate social hospitality.

Under any circumstances, a personnel, his/ her closely related person(s) should not accept or give a gifts in the form of cash or cash equivalent to a third party if it is made with the intention of influencing the third party when there is a pending business decision. Hence, the intention behind the gift or hospitality should always be considered, except if it is part of a customary practice and this should be limited to a nominal value which shall be done in an open and transparent manner

6.3 ENTERTAINMENT

The Group allows appropriate business related entertainment. Personnel are allowed to offer or accept entertainment/recreation of a moderate and reasonable value, which comes with proper justification, without the intention of influencing someone to act improperly, or as a reward for having acted improperly or in a position of conflict.

Business related entertainment is legitimate for business purposes and should not create a perception of expectation in an unfavourable or negative manner in exchange for any commercial outcome. The Group will not pay expenses for closely related person(s), i.e. spouse(s), family members, relatives or close associates who do not have a legitimate business purpose with the Group.

6.4 DONATIONS AND SPONSORSHIPS, INCLUDING POLITICAL CONTRIBUTIONS

The Group allows charitable donations and sponsorships including political contributions for legitimate reasons as permitted under applicable laws and regulations but subject to due diligence and the relevant management approvals.

6.5 TENDER PROCESS

Any bidding process participated by any company under the Group should be done in an appropriate and transparent manner according to the tender board procedures.

6.6 THIRD PARTIES AND AGENCIES

All third parties, includes without limitation to agents, consultants, contractors, subcontractors, suppliers and joint venture partners should be aware of this ABAAC Policy. The Group expects them to comply with the minimum standards and procedures relating to anti-bribery and anti-corruption.

7.0 AWARENESS

All personnel of the Group should be aware of the ABAAC policy especially regarding anti-bribery and anti-corruption to continuously promulgate integrity and ethics.

8.0 RECORD-KEEPING

The Group is required to keep detailed and accurate financial records with appropriate internal controls of all payments made to serve as evidence that such payments were bona fide, and not linked to corrupt or unethical conduct. The Group shall ensure all expenses claims relating to gifts, hospitality and entertainment including donations, sponsorships and expenses of similar nature be recorded, as such expenses are subject to Management review.

9.0 REPORTING OF VIOLATIONS OF THE POLICY

Any person who knows or suspects any personnel related to the Group violating the ABAAC Policy is strongly encouraged to report their concerns immediately under the Group’s Whistleblowing Protection Policy (WBP Policy) to mgt@llc-bhd.com without fear of retaliation or reprisal.

The Group is committed to the ABAAC policy and gives assurance that whistleblowers will not suffer any form of punishment, retribution, detriment or victimization so long as the reports are done in good faith and without malicious intent to damage the reputation of another person or the organization.

10.0 COMPLIANCE TO THE LAW

The Group will fully comply with all legitimate and applicable laws with regards to anti-bribery and anti-corruption acts. Non-compliance with this policy which involves the employee may be subject to stern disciplinary action including dismissal from employment.

For business associates and other related external parties, non-compliance may lead to penalties including termination of contracts. The Group reserves the right to report any actions or activities suspected of being criminal in nature to the police or relevant authorities including take further legal action in the event that the Group’s interests have been impacted by non-compliance of individuals and/or organizations.

This ABAAC Policy is approved by the Board of Directors of LLC Berhad on 01st Jan 2021.