Yutaka Shoji Malaysia Sdn. Bhd. (the Company) is committed to uphold all laws relating to anti-Bribery and anti-Corruption in Malaysia, in particular the Malaysian Anti-Corruption Commission (MACC) Act 2009.
The Company has adopted a zero tolerate approach against all forms of bribery and corruption in carrying out its business dealings and relationships within the Company.
The objective of the policy is to provide guidance and reference points in implementing and managing controls and procedures to prevent the occurrence of corrupt conduct.
To establish standards and guidance in accordance with the requirements and obligations imposed under the MACC 2009 and Guidelines on Adequate Procedures. MACC Guidelines is based on following five guiding principles ie TRUST
- Top level commitment
- Risk Assessment
- Undertake control measure
- Systematic Review, Monitoring and Enforcement
- Training and Communication
The principles and obligations of this Policy shall apply to all Associated Person of the Company. Associated Person shall include
- All Directors, employees and Agents (Personnel) of the Company, and
- All external parties of the Company such as vendors, consultants and independent service providers.
All employees working at all levels shall exercise good judgement and strictly comply with the following controls to mitigate corruption risks.
- Gifts and Entertainment must be unsolicited and should be offered/received in connection with customary business or cultural occasion.
- Lavish or unreasonable gifts and entertainments, including donations, contributions and sponsorships, whether directly or indirectly, with the intention of influencing to obtain business advantage or compromise their judgement or in exchange for benefits, is strictly prohibited.
- Giving or receiving commission, discount, rebate and interest in respect of business transacted, which is not in accordance to the Company’s policies and procedures.
- Actual or potential conflict of interest which could adversely affect the interest of the Company and its shareholders.
- Facilitation payments or kickbacks of any kind is strictly prohibited.
- All expenses and claims to be approved in accordance to the Company’s approving authority matrix.
The Company shall undertake due diligence to assess the integrity of Associated Person prior to entering into any formzalized relationship with them and updated periodically thereafter, ensuring that the Associated Person share the Company’s stance against corruption.
Review, Monitoring and Enforcement
Audit Committee shall review the Company’s anti-corruption programme to ensure its efficiency and effectiveness.
All Departmental Heads will monitor the compliance of their Personnel in relation to this Policy. Any non-compliance must be reported to Compliance Department and presented to the Board for review.
Appropriate disciplinary action will be taken against any Personnel who is found to be non-compliant with the Policy or involve in practices that may lead to corruption.
All the processes in relation to compliance of this policy shall be recorded and documented.
Training and Communication
Training on the understanding and importance of anti-bribery and anti-corruption policy must be conducted on a periodic basis for all Personnel to raise awareness of their roles and collective responsibility to mitigate corrupt practice.
Reporting Channel (Whistleblowing Policy)
Internal and external parties are encouraged to raise concerns in relation to any non-compliance or incidence of corruption. Please refer to the Company’s Whistleblowing Policy for details on how such concerns may be raised.