ANTI-BRIBERY POLICY

Our Anti-Bribery Policy

H&T Consulting Engineers Sdn. Bhd. / H&T BIM Digital Engineering Sdn. Bhd.  (“the Company”) has established a comprehensive Anti-Bribery Policy that applies to all employees, business associates, contractors, suppliers, and other interested parties involved in the Company’s operations.

The Company has a zero-tolerance approach to bribery and corruption and is committed to complying with the MACC Act and other applicable laws.

The Company will:

  1. Demonstrate leadership commitment by promoting a culture of integrity, ethical conduct, and compliance throughout the organisation.
  2. Encourage employees to raise concerns in good faith about suspected bribery or corruption and protecting them against retaliation, victimisation, or any form of reprisal.
  3. Cooperate fully with relevant authorities and complying with all legal, regulatory, and anti-corruption requirements, including the MACC Act.
  4. Promote continual improvement of the Anti-Bribery Management System (ABMS) in accordance with ISO 37001 and providing adequate resources for its effective implementation and maintenance.
  5. Regularly reviewing and enhancing the ABMS to ensure its continued effectiveness, legal compliance, and alignment with recognised business ethics and governance standards.

Any breach of this policy will be treated seriously and may result in disciplinary action, including termination of employment, termination of business relationships or contracts, and legal action where appropriate.

Anti-Bribery Commitment Statement

Our Commitment to Anti-Bribery

H&T Consulting Engineers Sdn. Bhd. / H&T BIM Digital Engineering Sdn. Bhd.  (“the Company”) is committed to conducting all business activities and operations with the highest standards of integrity, transparency, and accountability, while ensuring compliance with all applicable laws, regulations, and requirements, particularly ISO 37001 Anti-Bribery Management System (ABMS) and the Malaysian Anti-Corruption Commission (MACC) Act.

All Company personnel are strictly prohibited from:

  1. Offering, giving, soliciting, or accepting any gift, hospitality, donation or similar benefit that may influence, or appear to influence, a business decision or professional judgement.
  2. Using or accepting gifts, hospitality, donations or similar benefits to obtain or retain business, gain an improper advantage, influence a business decision, or receive favourable treatment.
  3. Engaging in any arrangement or activity involving gifts, hospitality, donations or similar benefits that may create an expectation of improper influence or preferential treatment.

Any violation of this Policy may result in disciplinary action, including a warning, suspension or termination, in accordance with applicable laws, regulations and Company procedures.

Where bribery, corruption or any other unlawful conduct is suspected, the Company may report the matter to the relevant authorities.

All personnel are required to uphold this Policy and to act with integrity and transparency in all business dealings.

Anti-Bribery Objective

No Anti-Bribery Objective Planning to achieve the Objective Measurement Responsibility Record Target Date
1. To achieve ZERO reported cases of bribery and corruption from Malaysian Anti-Corruption Commission (MACC) in a year.

 

 ·        Ensure all persons that is under “more than a low risk” to fill in declaration and due diligence form.

 

 Report Cases or Summons or Prosecution from MACC ABF Summons / Reported Cases Yearly
2. To propose at least 1 improvement plan relating to ISO 37001 in a year. ·        Issue improvement form for all departments to fill in

·        Collection of improvement form before Management Review Meeting

 

 Total no. of improvement plan All Staff PR-IM-02

/ Improvement Plan

 Yearly
3. To conduct at least 1 training relating to anti bribery / corruption awareness in a year. ·        Invite MACC officer to give talk on anti-bribery / corruption

·        Engage external training provider to provide such awareness training

·        Engage Anti-Bribery Function (ABF) to conduct internal training

 

 Total no. of internal / external training conducted Human Resource Annual Training Plan

FM-AM-06

FM-AM-07

FM-AM-14

 Yearly
4. To reply and take corrective actions on NCRs and/or OFIs raised by internal and external auditors within the defined timeline. ·        Ensure that internal audit is done in a fair manner.

·        All HODs to accept findings issued during the internal audit

·        The top management is willing to accept constructive improvement feedback from the auditors and committed to take actions to improve the ABMS

 

 Internal & External Audit Reports All Staff Internal Audit / External Audit Summary Report Yearly
5. To encourage any whistleblowing or complaints or improvement feedback from any employee, to provide at least one reward or positive recognition to any impactful positive/negative feedback person/year.

 

 ·        Provision of strict rules / disciplinary action against those who are guilty of corruption / bribery or reprisal of employees.

·        Encouraging employees to raise concerns in good faith on any areas of suspected bribery that is occurring by providing a positive recognition/reward

 Write in improvement feedback/ complaints / whistleblowing to Anti-Bribery Function (ABF) ABF Management Review Meeting Yearly

Reporting Concerns and Whistleblowing

Employees and stakeholders are encouraged to report any suspected misconduct through the Company’s whistleblowing channels. Reports will be treated confidentially, anonymous reporting is accepted, and the Company strictly prohibits retaliation against anyone who raises concerns in good faith.

Concerns may be reported through the following whistleblowing channels:

                                Level 36, HCK Tower (J-36-1), Empire City,
                                No. 8, Jalan Damansara, PJU 8,
                                47820 Petaling Jaya,
                                Selangor.