Elegant World Group Of Companies Anti-Bribery & Anti-Corruption (“ABC”) Policy

1.1  Elegant World Sdn. Bhd. and its Group of Companies (“the Group”) practices a strict zero-tolerance approach against bribery and corruption. The Group upholds a culture of integrity and all applicable laws in relation to anti-bribery and anti-corruption. The Group of Companies are as follows:-

  1. Elegant World Sdn. Bhd.
  2. Elken Sdn. Bhd.
  3. Elken Global Sdn. Bhd.
  4. Elken Service Sdn. Bhd.
  5. Butbo Sdn. Bhd. and
  6. Gene Express Sdn. Bhd.

1.2 This ABC Policy aims to set out the framework and parameters of reference and guidance to all Stakeholders (including but not limited to directors, distributors/members, suppliers, service providers, employees), whether they are working for or with the Group in complying with the applicable anti-bribery and anti-corruption laws.

1.3 “Bribery” and “Corruption” are 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 in violation of applicable laws), as an inducement or reward for a person acting or refrain from acting in relation to the performance of his/her duties.

2.1 No-Gift Policy

The Group has a “no gift policy” where all Stakeholders shall not provide, solicit and employees shall not accept gifts from any third party that may have direct/indirect business interest with the Group.  The word “gift” means any item (pens, calendars, hats, bags, angpau, etc) having any cost or financial value, including food or beverages, and including vendor-sponsored meals, parties or tickets to sporting and/or entertainment events. Thank you notes, certificates, or other written forms of recognition of our employees are allowed.

2.2 Entertainment & Hospitality

The Group is aware that the exchange of gifts can be a very delicate matter where, in certain cultures or situations, gift giving is a central part of business etiquette. However, the Group prohibits the giving and receiving of hospitality and/or entertain where it would be illegal or in breach of any applicable laws.

2.3 Donations and Sponsorships

As part of the Group’s commitment to provide financial/non-financial assistance for its corporate social responsibility initiatives, proper due diligence must be carried out to ensure that the contribution for the intended for association/organisation is legitimate and in accordance to Finance Policies and Procedures.

2.4 Facilitation Payments

The Group strictly prohibits giving (whether directly or indirectly) any facilitation and/or extortion payments in return for any business advantage for the Group.

2.5 Conflict of Interest

Conflict of interest may arise where a person’s objectivity could be interfered with when he/she is performing duties or exercising judgment on behalf of the Group, whether it is in relation to receiving or giving any benefit (in cash or in-kind) that could result in conflicting with their obligations or duties for any personal gain that could result in the Group’s benefit.

2.6 Procurement

Procurement must be conducted in accordance with the Group’s policies, internal processes and procedures relating to procurement. Stakeholders are prohibited from offering, promising, requesting, paying or receiving any form of bribe or facilitation of payment as part of the procurement process.

2.7 Tender

Any tender processes participated by any company shall be fair, transparent and in accordance with the Group’s tendering procedures.

3.1 The Group encourages Stakeholders to report any actual, suspected bribery/corruption occurring in the course of business/work, with supporting evidence/detailed information via email to abc.compliance@elken.com. Whistleblowing made in good faith will be given the protection of confidentiality and against retaliation. Anonymous complaints will not be entertained.

4.1 The Group will conduct a periodical risk assessment and review of its subsidiaries’ ABC standard operating procedures (“SOP”) at least once every three years to ensure that the Group of Companies continue to have relevant, appropriate and effective monitoring system to uphold the Group’s ABC policy.

4.2 An internal audit of the Group’s ABC compliances will be conducted from time-to-time. Any findings will be reported to and acted upon by the ABC Committee.

5.1 The Group communicates this ABC Policy to its Stakeholders (where appropriate and applicable) and trains its employees through various communication channels to ensure its ABC compliance are in accordance with the laws. A copy of the ABC Policy is made available at the Group’s corporate websites.

6.1 The Group views any violation of the ABC Policy and/or its corresponding SOPs seriously and upon investigation of any conduct found non-compliant or violates any applicable laws shall be reported to the ABC Committee and if proven may result in termination of contract, suspension/termination of employment or reporting of the criminal offence to MACC.

Elegant World Group Of Companies Whistleblowing Governance Policy

1.1 Elegant World (M) Sdn. Bhd. and its Group of Companies (“the Group”) are committed to conducting their business activities with integrity, high ethical standards and accountability.

1.2 This Whistleblowing Governance Policy (“Policy”) is developed to:- i) protect the values of integrity where the Group conducts its business activities; ii) establish a structured reporting channel and guidance for responding to any reports from Employees and Stakeholders regarding such potential violations or concerns; and iii) protect Whistleblower from reprisal and to safeguard the Whistleblower’s confidentiality.

2.1 “Whistleblowing” is a deliberate, voluntary disclosure/reporting (supported with evidence/detailed information) of an individual or company by a person, who has privileged access to information based on an actual or suspected Improper Conduct (defined hereunder) within the Group.

2.2 “Whistleblower” means any person who discloses information of Improper Conduct (as defined hereunder) in accordance with Policy.

2.3 “Improper Conduct” means any conduct which if proved, constitutes a violation of ABC Policy or laws or concealment of either or both.

 2.4   This Policy applies to the Group’s Employees and Stakeholders with an employment or business relationship with the Group.

2.5 This Policy does not apply to Employees’ grievances, which shall be dealt in accordance with Group Human Resource’s guidelines and policies.

2.6 Any Whistleblower who intends to lodge any report of Improper Conduct must have reasonable grounds for believing in its existence and must undertake such reporting in good faith and for the best interest of the Group.

2.7 The good faith element shall be deemed lacking if:- i) the person does not have personal knowledge or a factual basis for the report of Improper Conduct; or ii) the person knew or reasonably should have known that the reports are false, frivolous or vexatious; or iii) the report has been made with malicious intent, ulterior motive or for personal gain.

3.1 All reports shall be communicated in writing made through email (using the attached Appendix A: Whistleblowing Report”) to abc.compliance@elken.com. The report must provide full details of the Improper Conduct and where possible, with the supporting evidence/detailed information. Anonymous complaints will not be entertained.

4.1 Whistleblower who reports in good faith will be protected from any adverse and detrimental treatment and will be accorded with confidentiality of identity protection, to the extent reasonably practicable.

4.2 Any Whistleblowing not made in good faith and is found to be deliberately falsified with malicious intent will be subjected to appropriate disciplinary actions or legal repercussions, where appropriate.

5.1 The Anti-Bribery & Anti-Corruption Committee (ABC) will screen and assess the Whistleblower’s disclosure to determine whether it constitutes an Improper Conduct or is excluded from the scope of this Policy. The Whistleblower may be required to provide additional information and clarifications if required.

5.2 Based on the initial findings, ABC will decide on the next course of action whether to appoint authorised person(s) to carry out initial investigation, if required.

5.3 After investigation, ABC will determine the merits of the Whistleblower’s disclosure and decides, including but not limited to the following:

  1. Commencing a full investigation by setting up Whistleblowing Governance Committee (WGC) in the event that the preliminary findings clearly indicate a basis for further investigation; or
  2. Reject the Whistleblower’s disclosure if the preliminary findings indicate no basis for further investigation; or
  3. Determine any other course of action which the ABC deems appropriate.

Please refer to Appendix B for Whistleblowing Procedures Flowchart.

© Copyright 2024, ELKEN SDN. BHD. 199501005790 (334986-W)(AJL 93727)
ELEGANT WORLD (M) SDN BHD Reg. No. 198701006675 (165389-K)
All rights reserved.

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