Anti-Bribery and
Corruption Policy

Genting Simon Group
Anti-Bribery and Corruption Policy

General

1. 1. Overview
      
      In line with its policy against bribery and corruption, the Company has put in place the Anti-Bribery and Corruption System ("ABCS") to consolidate and manage elements, policies, objectives and processes in relation to bribery and corruption risks in the Group.
      
      The Anti-Bribery and Corruption Policy ("ABCS Policy") aims to set out the main principles, policies and guideline that the Company practices in relation to anti-bribery and corruption. This ABCS Policy is not meant to cover all possible situations that may arise in the course of business. This ABCS Policy is designed to provide a frame of reference and guidance to all persons working for and with the Company in observing and complying with the applicable laws on anti-bribery and corruption.
   2. What is "bribery" and "corruption"?
      
      "Bribery" and "corruption" refer to the offering, promising, giving, accepting or soliciting of an undue advantage or gratification of any value which can be financial or non-financial, directly or indirectly, and irrespective of location, in violation of applicable law as an inducement or reward for a person acting or refraining from acting in relation to the performance of the person's duties.

Gifts

It is the responsibility of employees and directors to inform external parties involved in any business dealings with the Company that the Company practices a "No Gift Policy" and to request the external party's understanding for and adherence with this policy.

Gifts are only permitted under the following situations:-

2. 1. Receiving gifts
      1. Gifts received from Company during internal or official Company events or functions
         Gift may be retained by the Personnel after declaring to the Compliance Officer.
      2. Gifts received at official external events or functions
         If the value of such gift exceeds RM 500 ("Gift Threshold"), the gift received must be approved by the Chief Operating Officer and be declared to the Compliance Officer. Gifts below the Gift Threshold must be declared to the Compliance Officer using the Declaration Form and may be retained by the Personnel after such declaration is made.
      3. When refusal will seriously offend a third party
         When refusing the gift is likely to seriously offend or severely affect the Company's business relationship with a third party, or when it is against business etiquette or is impractical to refuse gifts, the gift received must be approved by the Chief Operating Officer and be declared to the Compliance Officer.
      4. Token gifts of nominal value bearing company logo
         If the value of such gift exceeds the Gift Threshold, the gift must be approved by the Chief Operating Officer and be declared to the Compliance Office. Gifts below the Gift Threshold must be declared to the Compliance Officer using the Declaration Form and may be retained by the Personnel after such declaration is made.
      5. Gift and Donation Committee approves a gift
         In the event that the Chief Operating Officer approves the acceptance of such gift, Chief Operating Officer must then determine the treatment of the gift and the Personnel will be notified accordingly. In the event that the Chief Operating Officer does not approve the acceptance of such gift, the gift must be politely returned with a note explaining the Company's "No Gift Policy".
      6. Conflict of interest
         Where there is a conflict of interest, the gift must be politely returned with a note explaining the Company's "No Gift Policy".
      7. Record
         All gifts received must be recorded in the Gift Register along with supporting documents and kept by the Compliance Officer.
   2. Offering gifts
      1. Permitted gifts
         • Gifts offered to third parties during official Company events or functions;
         • Gifts offered to third parties as an exchange of gifts during official external events or functions (gift exchanged is treated as Company property);
         • Token gifts of nominal value usually bearing the Company's logo deemed as part of the Company's brand building or promotional activities;
         • Gifts offered in conjunction with any festive or occasion and in such an event the gift must not exceed the Gift Threshold. If the value of such gift exceeds the Gift Threshold, prior approval must be obtained from the Chief Operating Officer.
      2. Exercise proper judgment
         All Personnel, the respective Heads of Department, the Compliance Officer and the Chief Operating Officer are expected to exercise proper care and judgment, taking into account pertinent circumstances and the business context, applicable laws and cultural norms. No gift can be offered in return for any business advantage or disguised as a bribe.
      3. Record
         All gifts offered must be recorded in the Gift Register along with the supporting documents.

Hospitality and Entertainment

3. 1. Providing Hospitality and/or Entertainment
      1. All hospitality and entertainment provided are limited to business purposes only and must be cleared in accordance with the Company's Limits of Authority.
      2. The value of all hospitality and/or entertainment provided must not exceed RM 500 ("H&E Threshold") and in any event must not be more than 3 times a year to the same individual and/or company. Such payments and claims must be approved by the Limits of Authority approval and a copy of such documentation must be provided to the Compliance Officer. Any payment and claims made for any hospitality and/or entertainment exceeding the H&E Threshold or more than 3 times a year to the same individual and/or company must first be approved by the Limits of Authority approval and Chief Operating Officer and a copy of such documentation must be provided to the Compliance Officer.
      3. Personnel must obtain all necessary approval for issuance of complimentary tickets or passes to corporate hospitality events in accordance with the Company's Limits of Authority and declared to the Chief Operating Officer and a copy of such documentation must be provided to the Compliance Officer.
      4. Any hospitality and/or entertainment provided to any Public Officials, regardless of value, must first be approved by the Chief Operating Officer and a copy of such documentation is to be provided to the Compliance Officer.
      5. All claims for hospitality and/or entertainment provided must have supporting documents and where the approval of the Chief Operating Officer is required, a copy of the approval must be attached to the claim and will be processed in accordance with current finance policies for claims. All payments and claims made for any hospitality or entertainment along with the supporting documents must be recorded and kept.
   2. Receiving Hospitality and/or Entertainment
      1. The Company strictly prohibits its Personnel from soliciting hospitality or entertainment or accepting hospitality or entertainment given in response to or in anticipation of a favourable business decision.
      2. All Personnel are required to exercise proper care and judgment before accepting hospitality or entertainment offered or provided by third parties. This is not only to safeguard the Company's reputation, but also to protect the Personnel from allegations of impropriety or undue influence.
      3. When in doubt, you should either politely decline the offer or seek advice from your Head of Department, the Compliance Officer or the Legal Department.

Donations and Sponsorships

4. 1. As part of its commitment to corporate social responsibility, the Company provides such assistance in appropriate circumstances and in an appropriate manner. However, such requests must be carefully examined for legitimacy and not be made to improperly influence a business outcome for the Company.
   2. All sponsorships and donations by the Company must comply with the following principles:
      1. ensure such contributions are allowed by applicable laws;
      2. obtain all the necessary internal and external authorizations in accordance with the Company's Limits of Authority and approval from the Chief Operating Officer;
      3. be made to legitimate entities having an adequate organisational structure for proper administration of the funds;
      4. be accurately stated in the Company's accounting books and records; and
      5. not to be used as a means to cover up a bribery.
   3. Due diligence must be conducted by the requestor to ensure that the requests are legitimate and any red flags raised are solved prior to committing the funds.
   4. Any donations or sponsorship must first be approved by the Limits of Authority approval and the Chief Operating Officer. A copy of such documentation is to be provided to the Compliance Office.

Political Contribution

5. 1. Where political contribution is permitted, such contribution must be approved by the Board of Directors.
   2. The Company encourages employees to participate in the political election process by voting. Employees may choose to make personal political contributions as appropriate within the limits established by applicable law. Under no circumstances will any employee be compensated or reimbursed in any way by the Company for a personal political contribution.

Facilitation Payment and/or Extortion Payment

6. 1. What is "facilitation payment"?
      
      "Facilitation payment", often referred to as "Duit Kopi" is an illegal or unofficial payment made in return for services which the payer is legally entitled to receive without making such payment.
      
      This usually occurs as a payment to a Public Official or person who has authority to grant certification, licenses, permissions or permits, in order to secure or expedite such process. It is important to note that facilitation payments do not necessarily involve cash or other financial asset, it may be in the form of any advantage with the intention to influence a decision or an outcome.
   2. What is "extortion payment"?
      
      Extortion is the demanding of a gratification, whether or not coupled with a threat if the demand is refused.
      

Third Parties

7. 1. The Company expects all third parties dealing with the Company to share our commitment to zero tolerance against corruption by complying with all policies/SOP/guidelines in relation to the ABCS and all applicable anti-corruption laws. All third parties including suppliers, vendors, contractors, and service providers performing work or services for or on behalf of the Company will be provided with the Code of Business Conduct for Third Parties and shall be required to comply with the Code of Business Conduct for Third Parties and all other relevant policies.
   2. It is the Company's policy to conduct appropriate and adequate due diligence on all third parties before entering into any formal arrangements.

Employees

8. 1. The Company upholds the principle of workforce diversity, equal opportunity, non-discrimination and fair treatment in all aspects of employment. As such, the recruitment of employees shall be done in accordance with the established standards and procedures.
   2. It is the Company's policy that appropriate and adequate due diligence shall be conducted on all prospective employees. The type of due diligence conducted on prospective employees will be based on the risk profile of the position.
   3. During the course of employment, all Company employees and directors shall:
      1. comply with all policies/SOP/guidelines in relation to the ABCS;
      2. attend initial training and annual refresher trainings on the ABCS;
      3. declare any actual or potential conflict of interest through the Employee Conflict of Interest Declaration; and
      4. sign an Integrity Pledge to confirm their commitment to uphold the Company’s anti-bribery policies and comply with anti corruption laws.

Whistleblowing

9. 1. The Company encourages all its employees, business partners and customers to report any real and/or suspected bribery or corruption.
   2. Anyone who makes a report, complaint or disclosure about any real and/or suspected bribery or corruption is given the protection of confidentiality and will not suffer any detrimental action for making the report. This is provided that the report, complaint or disclosure is made in good faith, belief and without malicious intent.
   3. The Company has established a whistleblowing channel, which is designed to facilitate and allow all Company employees, business partners and customers to report any real and/or suspected bribery or corruption. The following is the dedicated email for whistleblowing: whistle@genting.com

Violation and Investigation

10. 1. Any conduct which is non-compliant or in violation of the ABCS Policy and/or policies/SOP/guidelines in relation to the ABCS is taken seriously and is subject to disciplinary action(including termination of employment) and criminal prosecution.
    2. Where non-compliance of the ABCS is detected or a complaint is received, the Whistleblower Hotline Committee shall oversee the investigation process.