Anti-Corruption and Anti-Bribery Policy

  1. Policy Statement

    Fourtitude.Asia has adopted a zero-tolerance policy against all forms of corruption and unethical practices. In upholding the highest standard of ethical conduct and integrity in every business activity, the Company is committed to fully comply with all laws and regulations which governs the Company’s business transaction and operation.

    We commit to implementing and enforcing effective measures in combating corruption and bribery. This Anti-Bribery and Anti-Corruption Policy serves as a guideline towards effectively prevent, monitor and manage bribery and corruption in our business process.

    This Policy is to be read in conjunction with Fourtitude.Asia’s Code of Ethics and Business Conduct and Whistleblower Policy, a copy of which can be obtained from the Company’s website at

    For any enquiry or any concern about the application of this Policy and for reporting of any potential or actual event of bribery or corruption, kindly contact our Compliance Team via the following Communication Channel: Email: compliance@fourtitude.asiaTel: 03-78806580

  2. Definition and Interpretation

    • “Third Party” means any third party who is not the Company’s employee or director and who is performing services for or on behalf of the Company including but not limited to contractors, partners, service provider, consultants, personnel and/or their respective employees and/or agents.

    • “Bribe” means anything of value given in an attempt to affect a person’s actions or decisions in order to gain or retain a business advantage. Anything of value include bonus, discount, reward, wages, vote, service, cash, entertainment, or other gifts or courtesies.

    • “Communication Channel” means the channel available for contacting with the Company’s Compliance Team, ie. email address: / Tel: 03-7880 6580.

    • “Company” means all companies within Fourtitude.Asia Group, ie. Fourtitude Asia Sdn. Bhd. and all its subsidiaries and affiliated companies.

    • “Compliance Team” means the Company’s internal team which is responsible in receiving and handling enquiry, concern raised or complaint lodged by a Party.

    • “Conflict of interest” means when a person’s own interests either influence, have the potential to influence, or are perceived to influence their decision making of the Company.

    • “Corruption” means any type of unethical behavior or abuse of power for personal gain. It includes bribery and other forms of misconduct such as fraud, embezzlement, and nepotism.

    • “Facilitation payments” means payments made to secure or expedite the performance by a person performing a routine or administrative duty or function such as payment of small sums of money to government officials to facilitate or expedite a routing.

    • “Kickbacks” are typically payments made in return for a business favour or advantage.

    • “Parties/Party” collectively means the Company’s employees, directors and personnel whether or not such person is an employee or non-employee and all Third Parties.

    • “Territory” means the country where the business transaction, employment services engagement is being entered into between the Company and the Parties/Party.

  3. Definition and Interpretation

    1. Purchasing and Procurement Process

      Any potential or actual conflict of interest during purchasing or procurement process must be declared to the Company. Any suspected improper behavior or conflict of interest that affects a purchasing or procurement process must be reported to the Compliance Team through the Communication Channel.

      Employees must follow the relevant standard and procedure of operation in relation to procurement process. Supplier selection should never be based on exchange of unfair advantage. Record keeping in accordance with the Books, Records and Internal Control Requirements is required.

    2. Gift, entertainment and hospitality

      Gift, entertainment and hospitality could be considered as a bribe if it is given or received with the intention of influencing someone to act improperly, as a reward for having acted improperly or for a favourable business or benefit.

        Examples of gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, invitations to events, functions, or other social gatherings, in connection with matters related to our business. Gifts, entertainment and hospitality are prohibited unless it falls within a permitted exception based on reasonable boundary. As a guideline to determine whether a gift, entertainment or hospitality is permissible, the following questions can be taken into consideration before you decide on whether to accept or reject a gift, entertainment or hospitality:

      • What is the intent – is it to build a relationship or is it something else? It should be rejected or should not be given if the answer is ‘yes’.
      • How would it look if these details were on a newspaper? It should be rejected or should not be given if it could be interpreted as a bribe for improper exchange of certain benefit.
      • What if the situation were reversed – would there be a double standard? It should be rejected or should not be given if answer is ‘yes’.
      • Transparency – is it comfortable for you to disclose to your colleagues about the gift, entertainment or hospitality in question? It should be rejected or should not be given if the answer is ‘no’.
      • Does it put you in a position of conflict? It should be rejected or should not be given if the answer is ‘yes’.
      • Does your acceptance or giving of a gift, entertainment or hospitality affect any pending business decision or enable any unmerited advantage? It should be rejected or should not be given if the answer is ‘yes’.
      • Does the gift, entertainment or hospitality are given so frequently until it put you or the recipient under an obligation? It should be rejected or should not be given if the answer is ‘yes’.
      • Is giving or acceptance of the gift is purely out of friendly gesture during cultural or festive occasion? If yes, it can be accepted provided if the value is not more than RM 200.
      • When one is unsure about whether a gift, entertainment or hospitality could be accepted or be given, one should seek decision from the Compliance Team via the Communication Channel.

        For the avoidance of doubt, any gift, entertainment or hospitality which is more than RM200 shall be declared to the Compliance Team with submission of a duly signed declaration form via the Communication Channel.

        Any gifts, entertainment or hospitality that has been received is required to be returned or refunded to the party who has given the said gift, entertainment or hospitality if it is found to have violated this Policy and/or the governing law.

    3. Facilitation Payment and Kickbacks

      Direct or indirect giving or accepting a Facilitation Payment and Kickbacks of any kind are strictly prohibited. Activity which have the tendency of leading to a Facilitation Payment or Kickbacks must be strictly avoided. Any invitation for Facilitation Payment or Kickbacks must always be refused and Party who come across with such invitation must notify the Compliance Team via Communication Channel immediately.

    4. Donation and Contribution

        Donation and contribution which is made on the ground of supporting corporate social responsibility in good faith is acceptable. There shall be no political contribution from company’s fund without prior authorisation. In general, donation or contribution which is made with intention to exchange for certain outcome in the business transaction is strictly prohibited. To cite some examples for reference, donation or contribution of the following nature are strictly not allowed:

      • with intention to exchange directly or indirectly any desirable benefit or outcome;
      • is or could reasonably be perceived as for the purpose of influencing a business decision and/or obtaining a benefit in a business transaction;
      • which is against the law; or
      • which is excessive.
    5. Third Party

      All Third Parties are expected to refrain from bribery and corruption. If any of the Third Parties is involving in bribery or corruption, Company shall have the right to terminate the relationship with such Third Parties immediately.

      The Company has the discretion to conduct due diligence with regards to any Third Parties which is having an existing business transaction with the Company or is going to enter into a business transaction with the Company. Such due diligence may include searching through databases, declaration about relationship with public officials and existence of any related party relationship that might create conflict of interest.

      The Company may require Third Parties to adhere to appropriate practices to prevent bribery and corrution. For this purpose, a code of ethics and business conduct which appropriately set out the guidelines and standards in this aspect may be furnished to the respective parties.

      The Company shall endeavor to include clauses in relation to anti-bribery and anti-corruption obligations and the right to terminate a contract on the ground of bribery or corruption incident in its business contracts.

    6. Books, Records and Internal Control Requirements

      Expenses must never be hidden or purposefully misclassified. Records must be kept for each transaction including those by way of cash payment or banking transfer. All Parties must ensure maintenance of accurate books, records and financial reporting. Each payment made or received will be justified by proper business reason. All claims from employees will be submitted in accordance with the policy and procedure under the monitoring of the delegated department and all expenditure claims will subject to supporting reason for incurrence of such expenditure.

      All business units must maintain an effective system of internal control and monitoring of each business transactions and record and ensure accuracy and completeness.

    7. Books, Records and Internal Control Requirements

        Public Officials” include:

      1. elected or appointed public official such as a member of a ministry of the government;
      2. political officer, candidate for public office, officer, or employee or individual acting for or on behalf of a political party or candidate for public office;
      3. an individual acting for and on behalf of a Public Official, agency or such other form of body which is performing a governmental role, or is owned by or controlled by government;
      4. a person acting for or on behalf of a public international organization;
      5. a member of royal family or military;
      6. any other individual who is a Public Official according to the definition given by the law.

      Parties who are dealing with Public Official must declare the same to the Company. Parties dealing with Public Officials and contract on behalf of the Company must make sure compliance with all applicable laws and regulations.

    8. Responsibility for the Policy

      The management of the Company sets the tone at the top providing leadership and support for implementation of this Policy and take responsibility for its effectiveness within the respective business units.

      Each department and business unit will set up their respective standard operation procedure and standard that ensure compliance of this Policy.

      All employees for respective business unit shall comply with this Policy at all time, failing which investigation will be conducted followed by disciplinary action including dismissal depending on investigation outcome.

      All Third Parties who are having a business transaction with the Company are required to adhere to this Policy.

    9. Training and Communication

      This Policy will be communicated to employees through training and awareness program which assist employees to understand and aware about how to implement and comply with this Policy. A copy of this Policy will be accessible by employees through employee’s portal; and will be accessible by external Party through the Company’s official website.

    10. Raise a Concern/ Complaint

      Party who suspects or is having any concern regarding a conduct to which this Policy may applied or who is aware about a potential or actual event of violation of this Policy should notify the Compliance Team immediately via the Communication Channel. All reporting or notification shall be made in good faith. All report or notification receipt will be treated with utmost confidentiality. If a Party believe that he/she had suffered any detrimental treatment following his/her refusal to involve in a bribery or corruption event, or because of the reporting he/she had made in good faith, such Party should raise such concern to the Company via the Communication Channel. All complaint or report made will be handled in accordance with the Whistleblower Policy.

  4. Abuse of Policy

    Any user who has been proven to have misused / abused the Policy shall be taken serious disciplinary action, including dismissal.

  5. Review and Update

    The Company will monitor, review and/or update this Policy partly or as a whole from time to time when it deemed necessary in order to ensure compliance with governing laws and regulations and effectiveness of its implementation.