I. Introduction
At AEON Credit Service (M) Berhad and its subsidiaries (“The Group”), we recognize the importance of upholding the highest ethical standards and maintaining a zero-tolerance approach towards bribery and corruption in all our operations. As such, this Anti-Bribery and Corruption Policy Statement serves as a declaration of our organization commitment to combatting bribery and corruption in all its forms.
Our organization operates with a clear understanding of the detrimental impacts that bribery and corruption have on trust, fairness, and societal well-being. We firmly believe that by establishing and adhering to robust anti bribery and corruption measures, we not only fulfil our legal and ethical obligations but also contribute to a more transparent and accountable business environment.
II. Scope
The policy set out in this document shall be complied with by all employees, business associates and members of the Board of Directors based on the responsibilities identified. Any violations of this policy may be considered a breach and could result in disciplinary action, including dismissal for employees, breach of contract or compensation claims for Business Associates, and termination or removal for Board of Directors members. Additionally, applicable legal penalties may apply.
III. Definitions
| Terms | Definition |
| Corruption | Abuse of power for personal gain. It is an act of giving or receiving of any gratification or reward in the form of cash or in kind of high value for performing task in relation to his or her job description. It can occur in various forms, such as bribery, embezzlement, nepotism, extortion, kickbacks, fraud and collusion. |
| Bribery | Bribery is a form of Corruption. It is an act of offering, promising, giving, accepting or soliciting of undue advantage of any value (which could be financial or non-financial) directly or indirectly, and irrespective of locations in violation of applicable law, as an inducement or reward for a person acting or refraining from acting in relation to the person’s duties. |
| Group | AEON Credit Service (M) Berhad and its subsidiaries. The Top Management team consists of the following: Managing Director; Executive Director; and Executive Officer. |
| Subsidiary (ies) Company | A subsidiary is a company that fully or partially owned or controlled by a parent or holding company. |
| External Provider | A company or an individual who providing products and services directly or on behalf of Group and Subsidiary. |
IV. Policy Statement
This Anti-Bribery and Corruption Policy signifies a commitment of AEON Credit Service (M) Berhad and its subsidiaries (“the Group”) in conducting its business with integrity, sincere and ethical manner.
Involvement in bribery and corruption can lead to reputational damage and loss of business opportunities. The Group is guided by the AEON Foundational Ideals and AEON Group Future Vision, which emphasize acting with integrity and sincerity. Therefore, Anti-Bribery and Corruption programs are essential components of the Group, specifying requirements and providing guidance to safeguard against bribery and corruption risk. This approach aligns with the AEON Financial Service Co., Ltd. (“AFS”) Group Basic Policy for Compliance. In upholding the above commitment, the Group shall:
- Adopt zero tolerance of all forms of bribery and corruption;
- Comply with and adhere to the provision of the Malaysian Anti-Corruption Commission Act 2009 (Act 694) and other applicable laws and regulations, rules, policies and procedures;
- Promote an appropriate anti-bribery culture and continual improvement;
- Uphold the values of transparency and provide whistleblowing channels to encourage reporting on any bribery and corruption practices in good faith; and
- Establish an independent compliance function to oversee the implementation of Anti-Bribery and Corruption programs.
On annual basis, the Management and Board shall review the Policy to ensure its continuing suitability, adequacy and effectiveness in line with the Policy of ABCMS adheres to AEON Foundational Ideals, AEON Group Future Vision and AFS Group Basic Policy for Compliance.
The Group shall impose appropriate actions against any violation to this policy in accordance with applicable laws and the Group’s policies & procedures.
V. Anti-Bribery Compliance Program
We take a zero-tolerance approach to bribery and corruption in all our operations. Our Anti-Bribery and Corruption Compliance Program is designed to prevent, detect and respond to instances of bribery and corruption wherever they may occur.
We are committed to upholding the highest standards of ethical conduct and integrity in all aspects of our business. We recognize that bribery and corruption not only undermine trust and fairness but also pose legal and reputational risks that can have far-reaching consequences. Therefore, we are dedicated to ensuring compliance with all applicable anti-bribery and corruption laws and regulations.
Our compliance program is built upon the following key pillars:
Policies and Procedures
We have established clear and robust policies and procedures that outline our expectations regarding ethical conduct, anti-bribery, and corruption. These documents provide guidance to all employees, contractors, and business partners on their responsibilities and obligations to prevent bribery and corruption.
Due Diligence
The Group shall assess the nature and extent of the Bribery and Corruption Risk in relation to specific transactions, projects, activities, business activities and employees falling within these categories. The assessment shall include any due diligence necessary to obtain sufficient information to assess the Bribery and Corruption Risk.
Monitoring and Oversight
We employ robust monitoring and oversight mechanisms to assess the effectiveness of our compliance program and identify any areas for improvement. This includes regular audits, internal controls and whistleblower mechanisms to encourage the reporting of potential violations.
Response and Enforcement
If a violation of our Policy of Anti-Bribery & Corruption Management System is identified, we are committed to take swift and appropriate action. This may include disciplinary measures, termination of contracts, and cooperation with law enforcement authorities, as necessary.
VI. Top Level Commitment
Our commitment to combating bribery and corruption begins at the highest levels of leadership. We recognize that fostering a culture of integrity and ethical conduct starts with the example set by Key Senior Management and the Board of Directors. Therefore, we are fully committed to establishing a standard and showcasing our unwavering dedication to anti-bribery principles.
Board of Directors (“Board”)
- Approve the Policy of Anti-Bribery & Corruption Management System.
- Ensure the AFS Group Basic Policy for Compliance and Policy of Anti-Bribery & Corruption Management System are aligned.
- Demonstrate leadership and commitment with respect to the Policy of Anti-Bribery & Corruption Management System in the Group and set at the Board.
Board Risk Committee (“BRC”)
- Recommend the Policy of Anti-Bribery & Corruption Management System to Board for approval.
- Ensure the AFS Group Basic Policy for Compliance and Policy of Anti-Bribery & Corruption Management System are aligned.
- Exercise reasonable oversight over the implementation of the Group’s Anti-Bribery & Corruption programs by Key Senior Management and its effectiveness.
- Review the Group’s Anti-Bribery and Corruption operations at planned intervals.
- Ensure resources needed for Anti-Bribery and Corruption programs are available.
Key Senior Management
- Review and endorse the Policy of Anti-Bribery & Corruption Management System for recommendation by BRC and approval by Board.
- Ensure the Policy of Anti-Bribery & Corruption Management System and its objectives are established, implemented, maintained, and reviewed to address Group’s bribery and corruption risk.
- Ensure the integration of Anti-Bribery and Corruption requirements into Group’s business processes.
- Ensure that the resources needed for Anti-Bribery and Corruption are available.
- Communicate the importance of effective Anti-Bribery and Corruption programs and conforming to the Policy of Anti-Bribery and Corruption Management System internally and externally.
- Ensure the Anti-Bribery and Corruption programs achieve its intended results.
- Promote anti-bribery and corruption culture and continual improvement within the Group.
- Encourage the use of reporting procedure for suspected and actual bribery and corruption.
- Report the Group’s Anti-Bribery and Corruption operations and serious allegations or systemic bribery to the BRC at planned intervals.
VII. RISK ASSESSMENT
Risk Management Department is responsible for evaluating and handling risks pertinent to the Anti Bribery and Corruption Management System (“ABCMS”) ensuring compliance with applicable standards and regulations and implementing necessary controls to mitigate identified risks. The Bribery & Corruption Risk assessment shall be reviewed and approved by Key Senior Management.
VIII. UNDERTAKE CONTROL MEASURES
Gift and Entertainment
The Group has adopted a “No-gift” Policy whereby all staff and their families’ members or relatives are prohibited from, directly and indirectly, receiving or providing gifts.
Gift definition refers to anything of value, monetary or non-monetary including but not limited to money, voucher, products or services received by and/ or given to staff and any family members or relatives.
Acceptance of gift, entertainment and hospitality from customers and business associates is not allowed. Gift received from customers and business associates shall be returned to the giver supported by the “No-Gift” Decline Letter, signed and issued by relevant Head of Group/ Division.
Donation & Sponsorship
Any donation/ sponsorship to political party or public official which are intended to influence, or could reasonably be perceived to influence, a tender or other decision in favour of the Group is strictly prohibited.
Any donation to charitable organization, the Group shall comply with the following requirements:
- appropriate approval in accordance with the Company Authority Matrix set by the Company and its subsidiaries;
- public disclosure of the total donation;
- compliance with applicable laws and regulations;
- recipient is a registered charitable organisation i.e. independent non-profit organisation that seeks to advance some public benefit;
- avoid making contributions immediately before, during or immediately after contract negotiations;
- undertake due diligence with satisfactory results, and satisfying the Key Principles as set out in Clause;
- shall be in accordance with the budget approved by the Company and within the Company Authority Matrix set by the Company and its subsidiaries.
Facilitation Payments
Facilitation payment is an illegal or unofficial payment made in return for services that the payer is legally entitled to receive without making such payment e.g. payment made to public official or person with a certifying function in order to secure or expedite the performance of a routine or necessary action, such as the issuing of a visa, work permit, license, custom clearance and etc.
Facilitation payment is strictly prohibited.
Conflict of Interest
We recognize that conflicts of interest can undermine our efforts to prevent bribery and corruption and compromise the integrity of our operations. Therefore, we are committed to identifying, disclosing, and managing conflicts of interest effectively to ensure that our anti-bribery and corruption efforts remain uncompromised.
Reporting Channel and Whistle Blowing Policy
Establish a robust, transparent and accountable communication channel for the public (whistle blower) to voice their concerns in an effective, responsible and secured manner when they become aware of actual or potential wrongdoings, malpractice and/ or irregularities that will cause the Group to fall short of our social and corporate responsibilities. The improper conducts shall include corruption, bribery, fraud, theft, or embezzlement.
The Group committed to create a secure, private, and confidential channel for whistle blower to lodge a report and the Group shall undertake swift, fair, and effective investigation and corrective measure to maintain the integrity and ethical behaviour within the Group and the trust of the public. Please refer to our Whistle Blowing Policy.
Financial Controls
The Group shall implement financial controls that manage Bribery and Corruption Risk, in accordance with the Company Authority – Company Level.
Non-financial Controls
The Group shall implement non-financial controls that manage Bribery and Corruption Risk with respect to areas such as Procurement, Operations, Sales, Commercial, Human Resources, Legal and regulatory activities, in accordance with relevant Group’s policies and procedures.
IX. TRAINING AND COMMUNICATION
Group had provided comprehensive training programs to educate employees and stakeholders about the risks of bribery and corruption and the importance of compliance with our policies and procedures. By fostering a culture of awareness and accountability, we empower individuals to recognize and report suspicious behavior.
