Governance & Assurance

Anti-Bribery & Corruption Policy

Hexagon Synergy (M) Sdn. Bhd. (“the Company”) is committed to conducting business with integrity, transparency, and accountability. This Anti-Bribery & Corruption (ABC) Policy reinforces company’s zero-tolerance stance towards bribery and corruption, ensuring compliance with the Malaysian Anti-Corruption Commission Act 2009 (MACC Act 2009) and other relevant laws. Compliance to the Policy is mandatory and will be monitored with a principle-based approach.

Objectives of the Policy

This policy aims to:

a) Clearly define bribery and corruption.

b) Provide guidelines for identifying and managing bribery and corruption risks.

c) Establish procedures for reporting violations.

Ensure compliance with applicable anti-corruption laws and regulations

Scope of the Policy

This policy applies to all directors, managers, employees, and any third parties acting on behalf of Hexagon Synergy (M) Sdn. Bhd.

Definition

a) Bribery: any action which would be considered as an
offence of giving or receiving ‘gratification’ under MACC Act 2009.

b) Corruption: the act of giving or receiving of any
gratification or reward in the form of cash or in-kind of high value for
performing a task in relation to his/her job description.

c) Gratification: As defined in Section 3 of the MACC Act
2009, “gratification” means—

i.
money, donation, gift,
loan, fee, reward, valuable security, property or interest in property being
property of any description whether movable or immovable, financial benefit, or
any other similar advantage;

ii.
any office, dignity,
employment, contract of employment or services, and agreement to give
employment or render services in any capacity;

iii.
any payment, release,
discharge or liquidation of any loan, obligation or other liability, whether in
whole or in part;

iv.
any valuable consideration
of any kind, any discount, commission, rebate, bonus, deduction or percentage;

v.
any forbearance to demand
any money or money’s worth or valuable thing;

vi.
any other service or favour
of any description, including protection from any penalty or disability
incurred or apprehended or from any action or proceedings of a disciplinary,
civil or criminal nature, whether or not already instituted, and including the exercise
or the forbearance from the exercise of any right or any official power or
duty; and

vii. any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (i) to (vi).

Policy Statements

a) Prohibition of Bribery and Corruption: The Company strictly prohibits all forms of bribery and corruption, whether direct or indirect, in all business dealings and relationships. Employees must not participate in any corrupt activity, such as extortion, collusion, breach of trust, abuse of power, trading under influence, embezzlement, fraud or money laundering.

b) Gifts, Hospitality, and Entertainment: Employees must avoid giving or receiving gifts, hospitality, or entertainment that could influence business decisions or impair independence. Any exceptions require prior approval from the immediate supervisor or head of department.

c) Facilitation Payments: The Company prohibits facilitation payments, which are unofficial payments made to secure or expedite routine governmental actions. Employees are expected to notify their immediate superior when encountered with any requests for a facilitation payment.

d) Donations and Sponsorships: Charitable donations and sponsorships must not be used as a means to conceal bribery. All such activities require prior approval from the executive director(s) and must be transparent and in accordance with the Company’s policies.

a) Dealing with Public Officials: Extra caution must be exercised when dealing with public officials to avoid actions that could be perceived as attempts to influence official decisions.

Responsibilities of Employees and Third Party

a) Employees must read, understand, and comply with this policy. They are required to avoid any activities that could lead to, or imply, a breach of this policy.

b) Managers and Supervisors hold additional responsibilities to create and maintain an open environment for employees to ask questions, raise concerns, and report misconduct. They must ensure that their teams understand and comply with this policy.

c) All third parties acting on behalf of the Company are expected to comply with this policy. Appropriate due diligence should be conducted before engaging any third parties.

Conflict of Interest

Conflicts of interest arise in situations where there is a personal interest that might be considered to interfere with that person’s objectivity when performing duties or exercising judgement on behalf of the company. Employees should avoid or deal appropriately with situations in which personal interest could conflict obligations or duties. Employees must not use their position, official working hours, company resources and assets for personal gain or to the company’s disadvantage.

Record Keeping

All financial records and supporting documents must be maintained with accuracy and completeness to evidence the Company’s transactions and compliance with this policy.

Training and Communication

The Company will provide regular training to employees to ensure understanding and compliance with this policy. This policy will be communicated to all employees and relevant third parties. Human Resources shall maintain all records of trainings for all employees.

Reporting Violations

Employees and third parties are encouraged to report any suspected violations of this policy through immediate superior for employee, and whistleblower@hexagonsgroup.com for third party, respectively. Reports will be handled confidentially, and there will be no retaliation against individuals making reports in good faith.

Compliance and Review

Compliance with this policy will be monitored regularly. The policy will be reviewed at least once every three years to ensure its effectiveness and relevance. Non-compliance may result in disciplinary action, including termination of employment or contracts.

Whistleblowing Policy

Hexagon Synergy (M) Sdn. Bhd. (HSSB) strives to conduct its business and operations with integrity, transparency, competence and professionalism while achieving the highest level of responsibility and excellence. To uphold this aspiration, company must detect and deal with improper conduct. Recognising the abovementioned values, HSSB provides avenue for all employees of HSSB and members of the public to disclose any improper conduct within HSSB. Whistleblowers who come forward in good faith with information on actual or potential improper conduct are protected under the Whistleblower Protection Act 2010.

Objective of the Policy

This policy provides an avenue for all employees and its contractors, consultants, suppliers, interns, customers and members of the public to report their concerns about any illegal, unethical or questionable practices by HSSB’s employees in confidence and without the risk of reprisal.

Scope of the Policy

This policy is established to provide a clear and secure avenue for employees and members of the public to report any misconduct or criminal offenses through an internal

reporting channel. It aims to promote transparency, integrity, and accountability within the organization by encouraging whistleblowing in a safe and confidential manner.

Misconduct or criminal offenses that fall under the scope of this policy include, but are NOT limited to, the following:

Fraud;
Bribery and Corruption;
Criminal offence;
Money laundering, financing of terrorism, tax evasion, financing of proliferation of weapons of mass destruction or violation of sanctions requirements;
Breach of company’s Code of Conduct by its officers and employees;
Non-compliance with regulatory requirements or the provisions of the laws administered by company, by any person;

It is advisable for a potential whistleblower to consider whether the alleged improper conduct to be disclosed to HSSB falls within any of the above, prior to making the report. Potential whistleblowers may wish to seek legal advice from a legal practitioner before making the disclosure to HSSB.

Protection to Whistleblower

HSSB is committed to provide the whistleblower protections as outlined under the Whistleblower Protection Act 2010. The following protections will be accorded to a whistleblower who makes a disclosure of improper conduct to HSSB in good faith:

a) confidentiality of information;

b) immunity from civil and criminal liability for the disclosure made; and

c) protection from detrimental action.

Revocation of Whistleblower Protection

The whistleblower protection does not extend to the following disclosures and will be revoked by HSSB pursuant to section 11 of the Whistleblower Protection Act 2010:

where the disclosures of improper conduct which are:

(i) frivolous or vexatious;
(ii) principally questioning the merits of government policy, including policy of a public body;
(iii) known to the whistleblower to be false or untrue; or
(iv) made solely or substantially to avoid dismissal or other disciplinary action;

where the whistleblower has participated in the improper conduct disclosed; or
where the whistleblower commits an offence under the Whistleblower Protection Act 2010.

Any person who makes a disclosure of improper conduct to HSSB, knowing or believing that any material statements in the disclosure is false or untrue commits a criminal offence under the Whistleblower Protection Act 2010.

a) confidentiality of information;

b) immunity from civil and criminal liability for the disclosure made; and

c) protection from detrimental action.

Procedure in Making a Disclosure

Any disclosure of improper conduct that concerns HSSB must be submitted through whistleblower@hexagonsgroup.com or made to any of the relevant Designated Person through the specific communication channels.

Whistleblowers are advised to make their disclosures in writing and to provide sufficient details which include the following:

(i) the type or description of improper conduct;

(i) the name of individuals who have committed or are involved in the improper conduct; and

the ‘how’, ‘what’, and ‘where’ in relation to the improper conduct including supporting documents or evidence, if any.

Feedback to Whistleblower

Whistleblowers are encouraged to provide their identities or contact details to facilitate HSSB to clarify or obtain further information for purposes of further investigation into the improper conduct. Any person who chooses to remain anonymous is advised that no whistleblower protection will be accorded and HSSB’s ability to investigate the alleged improper conduct is limited to the extent of the contents of the report received by HSSB.

Whistleblowers will be informed by the Designated Person of the outcome of the investigation and action taken, if any, by the appropriate disciplinary authority or the other appropriate authority, the employer or the other appropriate person or the Public Prosecutor, as the case may be.

HSSB reserves the right to amend this policy from time to time.