Genting Simon Group
Anti-Bribery and Corruption Policy

Policy Statement

The Genting Simon Group, consisting of Genting Simon Sdn. Bhd., Genting Highlands Premium Outlets Sdn. Bhd., and all of its respective Malaysian subsidiaries as may be established from time to time (collectively referred to as the "Company"), is committed to conducting its business professionally, ethically and with the highest standard of integrity. The Company practices a zero-tolerance approach against all forms of bribery and corruption, and upholds all applicable laws in relation to anti-bribery and corruption.


General


Gifts

As a general rule, the Company practices a "No Gift Policy". Save as allowed under this ABCS Policy, all Personnel are prohibited from receiving and/or offering gifts whether directly or indirectly, and must immediately refuse and/or return such 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:-


NOTE:

For the avoidance of doubt, all Personnel are strictly prohibited from receiving and/or offering the following, whether directly or indirectly:-

  1. Any gift of cash or cash equivalent, including vouchers, discounts, coupons, shares and commission;
  2. Any gifts involving parties engaged in a tender or competitive bidding exercise;
  3. Any gifts that comes with a direct/indirect suggestion, hint, understanding or implication that some expected or desirable outcome is required in return for the gift;
  4. Any gift that would be illegal or in breach of applicable laws on bribery and corruption;
  5. Any gift which is lavish and/or excessive or may adversely tarnish the reputation of the Company.

Hospitality and Entertainment

The Company recognizes that it is a common practice to provide modest hospitality and entertainment to build and foster business relationships. However, all hospitality and/or entertainment, if received, in connection with the Company’s business, must be unsolicited and must not be perceived as a form of bribery.


NOTE:

For the avoidance of doubt the Company strictly prohibits the giving and receiving of hospitality and/or entertainment in the following situations:-

  1. Any hospitality and/or entertainment provided or received with a view to improperly cause undue influence on any party in exchange for some future benefit or result;
  2. Any hospitality and/or entertainment provided or received with a direct/indirect suggestion, hint, understanding or implication that some expected or desirable outcome is required;
  3. Any hospitality and/or entertainment involving parties engaged in a tender or competitive bidding exercise;
  4. Any hospitality and/or entertainment provided or received that would be illegal or in breach of any applicable laws;
  5. Any hospitality and/or entertainment that are sexually oriented;
  6. Any hospitality and/or entertainment provided or received that would be perceived as lavish or excessive or may adversely tarnish the reputation of the Company.

Donations and Sponsorships

As a responsible corporate citizen, the Company is committed to contributing to the well-being of the people and the country where it operates. However, the Company recognises that providing donations and sponsorships can pose a bribery risk as it involves payments to a third party without tangible return. As such, all donations and sponsorships are to be made in accordance with the Company’s policies.

NOTE:

For the avoidance of doubt, donations and sponsorship are strictly prohibited in the following situations:-
  1. Any donation or sponsorship request that comes with a direct/indirect suggestion, hint, understanding or implication that some expected or desirable outcome is required;
  2. Any donation or sponsorship that is illegal or in breach of any applicable laws;
  3. Any donation or sponsorship that may otherwise tarnish the reputation of the Company.

Political Contribution

As a general rule, the Company does not make political contributions, whether in the form of direct financial support, pledges or through the use of its assets to support any political candidate, incumbent or party. In limited circumstances, the Company may make political contributions in countries where such contributions are permitted by law.


Facilitation Payment and/or Extortion Payment

The Company strictly prohibits accepting or giving, whether directly or indirectly, any facilitation payments or extortion payments in return for any business advantage for the Company.



Third Parties


Employees


Whistleblowing


Violation and Investigation