ANTI-BRIBERY and Corruption policy

TESTBITS ANTI-BRIBERY & CORRUPTION POLICY

INTRODUCTION

This policy is in effect since 20 February 2017 and was last revised on 30 June 2020.

Testbits Sdn. Bhd adopts a ZERO-TOLERANCE approach towards bribery and corruption of any and all forms. We are committed to conducting business ethically and in compliance with all applicable laws and regulations of Malaysia and similar laws in other countries that prohibit improper payments, gratuity, gifts and any and all similar forms to obtain a business advantage. This document describes Testbits’ Policy prohibiting bribery and other improper payments in the conduct of Testbits’ business operations and employee responsibilities for ensuring implementation of the Policy. Questions about the Policy or its applicability to particular circumstances should be directed to our Compliance Officer.

This prohibition applies to all business activities, anywhere in the world, whether involving government officials or other commercial enterprises. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals, companies and all parties involved to possible criminal prosecution, reputational harm or other serious consequences. This Policy applies to everyone at Testbits, including all officers, employees and agents or other intermediaries acting on Testbits’ behalf, and to all individuals, clients and parties conducting business with Testbits. Each officer and employee of Testbits has a personal responsibility and obligation to conduct Testbits’ business activities ethically and in compliance with all applicable laws based on the countries wherein Testbits conducts business.

Failure to adhere may result in disciplinary action, up to and including dismissal, including lawful pursuit with appropriate authorities in accordance with the laws of Malaysia and similar laws in other countries.

DEFINITION(S)

Testbits define “improper payments” as the following; bribes, kickbacks, excessive gifts or entertainment, inappropriate & unjustified discounts, or any other payments made or offered of any and all forms, made or offered to obtain an undue business advantage. For example; giving monetary gifts, of monetary value objects such as properties (house, car, shares etc) and similar non-monetary gifts and properties.

These payments should not be confused with reasonable, appropriate and limited expenditures for gifts, business entertainment, business hospitality and other legitimate activities directly related to the professional conduct of Testbits’ business and services. For example; gifting pens and notebooks and providing lunch to student participating in Testbits’ Training Program.

RESPONSIBILITIES OF TESTBITS PERSONNEL

All of Testbits’ personnel are required to effectively execute the responsibilities and obligations of Testbits’s anti bribery & corruption policy which includes;

  • Understanding the requirements of the Policy and the laws and regulations applicable to the conduct of business;
  • Promptly record all transactions, payments and agreements in official records with accuracy and detail;
  • To flag and raise suspicious conduct, activities and transactions to superiors for immediate action;
  • Immediately report violations of this policy, and the laws and regulations of Malaysia through the appropriate channels
  • And to not misuse and abuse the “Testbits” name for personal gain.
  • When dealing with Business Associates, clients, customers, Testbits Personnel shall not
  • Express nepotism of any form for certain parties;
  • Offer remuneration, promises, benefits in order to obtain an advantage, influence decisions, and any similar rewards;
  • Conducts with conflicts of interests, criminal interests, such as extortion, blackmail, scandals;

POLICY MAINTENANCE

This policy may change without notice to improve adherence to all regulations and law of Malaysia and similarly in other countries.

REPORTING

Testbits encourages whistle-blowing to deter bribery and corruption. To report on suspicious activities, please reach out to Testbits at;

email:             contactus@mytestbits.com

phone:           +60376229581

                       +60192340489

All reports shall be handled with strict confidentiality and protection of the anonymity of the sender. The report(s) shall be addressed accordingly with the appropriate authorities and management.