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178  MSM MALAYSIA HOLDINGS BERHAD             WHO WE ARE     STATEMENT & DISCUSSION BY OUR LEADERS   HOW WE OPERATE
          ANNUAL INTEGRATED REPORT 2021

            GOVERNANCE

            INITIATIVES










                                                                 Anti-Bribery & Anti-Corruption

                                                                 Over the reporting year, MSM has been focusing on
                                                                 improving its anti-bribery measures and compliance.
                                                                 The Board has oversight over the Groups  Anti-Bribery &
                                                                 Anti-Corruption initiatives captured through the various
                                                                 approved anti-bribery related policies which is summarised
                                                                 in the  Anti-Bribery Policy Statement (4  October 2021),
                                                                                                   th
                                                                 which  aims  to  uphold MSM’s commitment  to prevent
                                                                 corruption and bribery and mitigating the risk of bribery and
                                                                 corruption within the Group, as prescribed by Bursa’s Main
            Ethical Business Conduct                             Market Listing Requirements & Guidelines on  Adequate
                                                                 Procedures for Corporate Liabilities as provided under the
            MSM  has  recently  launched  the refreshed  CoBCE  which   Malaysian  Anti-Corruption Commission (MACC)  Act 2009
            establishes clear expectations for employee compliance    (Amendment Act 2018).
            with MSM’s policies, and applicable laws and regulations
            related to lawful and ethical business practices. These reflect   The  Anti-Bribery Policy Statement is a general statement
            a culture of trust, integrity, transparency, holds employees   addressing corruption including bribery comprehensively
            accountable for their behaviour and helps employees    in seven specific policies and code: CoBCE,  APID,
            determine when and where to seek advice.  The CoBCE    Whistleblowing, Referral, Conflict of Interest, Sponsorships
            applies to all employees of the MSM Group. For all new     & Donations and the GEH. Some examples of related bribery
            employees, the contents  of the CoBCE  are covered  under   and corruption activities are covered under the GEH, a Policy
            their  onboarding programme and are expected to be signed   which aims to eliminate solicitation and bribery that may arise
            and acknowledged for Human Resources department’s record.   in the cause of giving and receiving of gift, entertainment
                                                                 and  hospitality.  Sponsorship  and  Donations  Policy  provides
            The CoBCE applies the following six universal principles on   guideline on the framework by which corporate sponsorships
            business practices following the Malaysian Business Code of   and donations shall be evaluated and the procedures by which
            Ethics (Rukun Niaga):                                decisions regarding corporate sponsorships and donations
                                                                 shall be made.
            1             2                    3                 7 Policies in the

              Honesty in
                                                Geniality
                            Responsible Towards
              Business      Customers, Society   Towards Fellow
              Dealings      and Environment     Humans           Anti-Bribery Policy Statement
                                                                        Whistleblowing             Code of Business
                                                                        Policy                     Conduct and Ethics

                                                                        Asset/Personal
                                                                        Interest Declaration       Conflict of
                                                                        Policy                     Interest Policy
            4             5                    6                        External Gift,

                            Fair Treatment
              Moderation
                                                Zeal in Making
              in Business   Towards Suppliers   the Business a          Entertainment &            Referral Policy
              Conduct       and Customers       Success                 Hospitality Policy
                                                                        Sponsorships &
                                                                        Donations Policy
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