Anti Bribery and Corruption Policy

1.1 AMS Advanced Material Berhad (the “Company”) and its subsidiaries (collectively referred as the (“Group”) are committed to high standards of ethical, moral and legal business conduct. The Company requires Directors and employees of the Group to commit to act professionally with integrity in all its business dealings.
1.2 This Anti-Bribery and Corruption Policy & Procedures (“ABAC Policy”) is aimed to prevent the occurrence of bribery and other corrupt practices and related issues that may arise in the course of business of the Group. The Company will also take appropriate and reasonable measures to ensure its business does not involve in corrupt activities.
1.3 This ABAC Policy applies to all companies within the Company, including all Directors, employees, and agents.
1.4 This ABAC Policy shall be read in conjunction with the Group’s various policies/procedures/guidelines/manuals/Code of Ethics & Conduct, as amended from time to time.

1. It is serve as a framework for the Directors, employees and agents on how to recognise and deal with bribery and corruption may arise;
2. To set out the guideline for the Directors, employees and agents to adhere to or comply with all applicable laws, rules and regulations to which they are bound to observe in the performance of their duties.

1. Any person/agent who corruptly solicits/accepts/agrees to accept gratification as an inducement of a reward to do or not to do an act in relation to a transaction or any official act of his principal or employer.
2. Any person/agent who corruptly offers/gives gratification as an inducement or a reward for any person/agent to do or not to do an act in relation to a transaction or any official act of his principal or employer.

1. 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;
2. any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
3. any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;
4. any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;
5. any forbearance to demand any money or money’s worth or valuable thing;
6. 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
7. any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f).

3.3 Gratification can take the form of cash, gifts, financial benefits, rights in action, property, privilege, emolument, loans, fees, rewards, courtesies or any other similar advantages.

4.1 This ABAC Policy does not prohibit normal business hospitality, and encourage the use of good judgement, discretion and moderation when giving or accepting gifts or entertainment in business settings.
4.2 GEH practices may vary in different cultures; however, any gifts and entertainment given or received must be in compliance with the law, must not violate the giver’s and/or receiver’s policies on the matter, and be consistent with local custom and practice.
4.3 All benefits given or received must be within the following conditions:
4.3.1 Reasonable in value
4.3.2 Infrequent in nature
4.3.3 Transparent and open
4.3.4 Not given to influence or obtain an unfair advantage
4.3.5 Respectful and customary
4.3.6 Legitimate and justified business courtesy
4.4 As a general principle, the Directors, employees and agents should not accept or give a gift to a third party with the intention of influencing the third party to obtain or retain business or in exchange for favours or benefits. In addition, lavish or unreasonable gifts or hospitality should not be accepted as such gifts or hospitality may be perceived or interpreted as attempts by the Directors, employees or agents to obtain or receive favourable business treatment for personal benefits.

5.1 Charitable donations and CSR initiatives as part of the contributions to the communities are acceptable whether of in-kind services, knowledge, time or direct financial contributions. However, Directors, employees and agents must ensure that the donations and contribution are not used as a scheme to conceal acts of corruption. All donations and contributions made must be pre-approved by an Executive Director.

Directors, employees and agents must declare all gifts or hospitality accepted or offered, and submit the details to their respective Human Resources Department for record.

7.1 The Group will comply with all applicable laws, rules and regulations of any jurisdictions in which the Group operates. Directors, employees and agents are expected to understand and comply with the Malaysian Anti-Corruption Commission Act 2009, including any amendment thereof. The Group reserves the right to report any actions or activities suspected of being criminal in nature to the police or other relevant authorities.

7.2 Directors, employees and agents will be accountable whether he/she pays a bribe himself/herself or whether he/she authorizes, assists or conspires with someone to violate the anti-corruption and bribery law.

8.1 Any employees, business associates and other stakeholders of the Group are encouraged to report in good faith, any suspected, attempted or actual corruption incidents through accessible and confidential trusted reporting channels. Written complaint must be made in writing using the Anti-Corruption Report Form as set as Appendix I or Whistleblowing Report Form which can be downloaded from the website at amsmetal.com.my and sent via any one of the following channels:

Email: [hrmd@ams.com.my]