HW Barakah Anti-Bribery Policy 

HEAP WAH BARAKAH SDN BHD mission is to conduct our business activities ethically and honestly, with zero-tolerance for all forms of bribery and corruption, whether direct or indirect, public or private.

We strive to achieve excellence by: 

• Prohibiting bribery in any form, including offering, giving, requesting, or receiving anything of value to improperly influence a decision or gain an unfair advantage.
• Complying with all relevant anti-bribery and corruption laws, regulations, rules, policies, procedures and voluntary commitments.
• Implementing and continuously improving an anti-bribery management system (ABMS) in accordance with ISO 37001:2025.
• Encouraging the good faith reporting of bribery-related concerns or suspicions, with assurance of confidentiality and protection against retaliation.

We shall ensure that ABMS objectives are established and that the ABMS Policy and Objectives are regularly reviewed to ensure their ongoing relevance and effectiveness.  We use data-driven insights to identify areas for improvement and implement corrective actions as needed.

We shall ensure that this ABMS policy is communicated and understood by every employee, interested parties, and business associates. We will encourage their active participation in maintaining and enhancing the integrity in our services.

OUR GIFTS, HOSPITALITY & ENTERTAINMENT POLICY

Business Associates must ensure that any gifts or hospitality provided are reasonable, appropriate, and proportionate to the business context, and are offered transparently without any intention to improperly influence, induce, or reward decisions or actions. Under no circumstances are cash or cash equivalents permitted. All gifts and benefits must fully comply with applicable contractual obligations, internal policies, and relevant laws and regulations. Gifts offered to the organization or to any department may be accepted only where they are of modest value, transparent, infrequent in nature and non -obligatory.

OUR CONFLICT OF INTEREST POLICY

Business Associates must conduct their activities with integrity and transparency at all times. They must avoid situations where personal interests conflict, or may be perceived to conflict, with business decisions, disclose any actual, potential, or perceived conflicts of interest, and refrain from maintaining undisclosed relationships with employees, officers, or officials that could improperly influence judgement or decision making.

1) Conflict of Interest

A conflict of interest may arise in circumstances including, but not limited to, the following: equity ownership in privately owned entities that have a business relationship with HWBSB; holding directorships, partnerships, or other forms of beneficial interest in entities that have a business relationship with HWBSB; other employment, business appointments, or undertakings that demand excessive time and attention and interfere with duties to HWBSB; personal relationships where a family member of an employee has a reporting relationship with the employee; contractual dealings where HWBSB purchases or leases property, equipment, materials, or services from directors or employees other than standard employment contracts; dealings with competitors where an employee or a family member has financial or other interests, involvement in a competitor’s business, or holds a directorship in a competing entity that could give rise to a conflict; involvement in activities where the director or employee concerned is the subject of the discussion or where the decision directly involves them. In addition, the acceptance of gifts, entertainment, or hospitality may affect an employee’s objectivity and judgement and may result in a conflict of interest.

2) Dealing with Conflict of Interest Declaration

Any actual or potential conflict of interest must be declared by completing the Conflict of Interest Declaration Form. Employees are responsible for making such declarations annually, or immediately when a conflict arises, and at the earliest opportunity upon becoming aware of the conflict. The completed Conflict of Interest Declaration Form must be submitted to the Anti Bribery Function for further review and action. As best practice, conflicts should be avoided wherever possible, for example by relinquishing the interest that gives rise to the conflict. Where it is not practical to completely avoid the conflict, appropriate mitigating actions must be taken based on the nature and severity of the conflict.

Where the conflict does not occur frequently and the impact is assessed to be low, the employee’s participation in the relevant decision making process shall be restricted. Such restrictions may include, but are not limited to, not participating in critical criteria setting or decision making roles, refraining from discussions on the matter, limiting or restricting access to information and denying access to sensitive or confidential documents, abstaining from voting on the decision, and executing non disclosure or confidentiality agreements to protect confidential, proprietary, or trade secret information.

Where the conflict is ongoing or may result in serious implications for the organization, the employee concerned must be removed from the process. This may include continued restrictions, complete abstention from any involvement, limitation or denial of access to information, reassignment or transfer of the employee, execution of non disclosure or confidentiality agreements, or resignation, depending on the circumstances.

REPORTING OF BRIBERY (WHISTLEBLOWING) AND INVESTIGATION

Business Associates are required to promptly report any suspected or actual bribery, any requests for bribes, as well as any ethical concerns or breaches of company policies. Reports may be made through the designated reporting channels, namely the Ethics or Integrity Hotline via WhatsApp at 012 8802833, or by email to heapwahhr@yahoo.com.

Anonymous reporting is permitted, and all reports made in good faith will be protected from retaliation. All reported cases will be investigated in a confidential manner, and appropriate corrective or disciplinary actions will be taken where necessary. Business Associates are also required to fully cooperate during any investigation arising from such reports.

CONSEQUENCES OF NON-COMPLIANCE

In the event of non compliance or misconduct, the organization may undertake a review of the business relationship and the associated contractual status. Where appropriate, the engagement may be temporarily suspended or restricted. Corrective actions will be implemented in accordance with applicable laws and regulations, and the organization may seek recovery of losses where this is contractually or legally permissible. Such actions may also result in potential reputational impact and affect future business opportunities.

COMMITMENT AND ACKNOWLEDGEMENT

Business Associates are expected to understand and comply with all ABMS and anti bribery requirements, conduct business in an ethical and transparent manner, and formally acknowledge and commit to upholding all applicable anti bribery obligations in the course of their business relationship with the organization.