Pacific & Orient Insurance Co. Berhad (“P&O”) has adopted a zero-tolerance approach to all forms of corruption and bribery. P&O is committed to conduct its business with the highest level of integrity and ethics and to comply with applicable laws, rules and regulations on anti-bribery and anti-corruption.

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

The Anti-Bribery and Anti-Corruption Policy (“Policy”) was established and adopted by Pacific & Orient Berhad and its Group of Companies (“the Group”). This Policy should be read in conjunction with the following P&O’s various policies, copies of which can be obtained at www.poi2u.com :- 

(a) Board Charter; 

(b) Corporate Disclosure Policy; and 

(c) Whistleblowing Policy;

as well as the Malaysian Anti-Corruption Commission Act, 2009 and its 2018 amendment (“MACC Act”) and any other local anti-bribery or anti-corruption laws that may be applicable.

This Policy applies to all Directors and Employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, protégé pupils, seconded staff, casual workers, agency staff, volunteers, interns, agents, sponsors or persons associated with the Group, or any of the subsidiaries or their employees, no matter where they are located.

For purposes of this Policy, an “Associated Person” shall refer to any individual or organisation who performs services for or on behalf of the Group. This may include but not limited to suppliers, contractors, agents, consultants, outsourced personnel, distributors, advisers, including their advisors, representatives and officials.

Definition of Bribery and Corruption

Bribery and corruption can be defined as any action which would be considered as an offence of giving or receiving ‘gratification’ under the MACC Act. “Gratification” as defined in the MACC Act means:- 

(a) 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; 

(b) any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;

c) any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part; 

(d) any valuable consideration of any kind, any unlawful discount, commission, rebate, bonus, deduction or percentage; 

(e) any forbearance to demand any money or money’s worth or valuable thing; 

(f) 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

(g) any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f).

Bribery and corruption can take many forms including the act of giving, offering, promising, providing, requesting/soliciting, accepting or agreeing to receive cash or other forms of financial assets or cash equivalents such as property, loan guarantee, or they can be any kind of advantage such as gift, entertainment, travelling benefits, accommodation or other services to an individual and/or their friends and family members - with an intention of inducing or rewarding someone to behave improperly or not to perform the functions correctly or in good faith.

REPORTING CONCERNS

The Group practices an open-door policy and encourages all Employees to share concerns and suggestions with their Heads of Department (“HOD”) who are able to address them in an appropriate manner. If any Employee / External Party suspects that there is an instance of bribery or corrupt activities occurring in relation to his/her employment, the Employee / External party is encouraged to raise his/her concerns at as early a stage as possible using the reporting channel stated in the P&O’s Whistleblowing Policy or email to whistleblower@pacific-orient.com and attach the Whistleblowing Form which can be obtained at https://www.poi2u.com/assets/document/whistle-blowing-form.pdf

If the Employee is uncertain about whether a certain action or behaviour can be considered bribery or corruption, he/she should speak to the Director or HOD or appropriate channels available.

In addition, under circumstances of suspicious behaviour, allegations and/or investigation relating to bribery or corruption, the Group Human Resource Department reserves all rights to request the relevant Employee to declare information regarding assets owned or family ties and relationships as relevant and as deemed necessary. 

If an Employee refuses to accept or offer a bribe or report a concern relating to potential act(s) of bribery or corruption, the Group understands that the Employee may feel worried about potential repercussions. The Group will support any Employee who raises concerns in good faith under this Policy, even if an investigation finds that he/she was mistaken.

The Group will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

If an Employee has reason to believe that he/she has been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, the Employee must promptly notify the HOD or appropriate channels for guidance on the next course of action. 

Please be guided accordingly.