Anti-Bribery Policy

1. Purpose

Strongbox Tech Sdn. Bhd. 201401036253 (1112392-X) (“Tech Strongbox”) is committed to conducting business with integrity, transparency, and fairness. We uphold a strict zero-tolerance policy against all forms of bribery and corruption. This policy sets out our responsibilities and the standards we expect of all employees, directors, contractors, agents, and business partners.

2. Scope

This policy applies to:

  • All employees (permanent, contract, temporary and interns).
  • Directors and shareholders.
  • Consultants, contractors, suppliers, vendors, agents and related companies acting on behalf of Tech Strongbox.
  • Any third party representing or connected to Tech Strongbox.

3. Definition of Bribery

Bribery is the offering, giving, receiving, or soliciting of anything of value to improperly influence the actions or decisions of another person or entity. This includes cash payments, gifts, entertainment, donations, kickbacks, or any undue advantage.

4. Prohibited Practices

The following are strictly prohibited:

  • Offering or accepting bribes: Directly or indirectly offering, promising, giving, or accepting any form of payment, benefit, or advantage to gain an improper business advantage.
  • Facilitation payments: Small, unofficial payments to speed up routine actions are not allowed.
  • Improper gifts or hospitality: Gifts, meals, or entertainment that are excessive, inappropriate, or intended to influence business decisions.
  • Political contributions: Company funds must not be used for political donations.
  • Charitable donations: Contributions must not be used as a cover for bribery.

5. Gifts, Entertainment, and Hospitality

Modest gifts and hospitality may be permitted if they are reasonable, proportionate, and transparent, and do not create an obligation or expectation. Any gift or entertainment above RM1,000.00 must be declared to and approved by the management.

6. Roles and Responsibilities

  • Employees: Must comply with this policy and immediately report suspected violations.
  • Managers: Responsible for ensuring their teams understand and follow this policy.
  • Compliance Officer/HR/Management: Oversees policy enforcement, record-keeping, and training.

7. Reporting and Whistleblowing

Employees and third parties are encouraged to report any suspicion of bribery or corruption to: hello@techstrongbox.com.

Reports will be treated confidentially, and retaliation against whistleblowers is strictly prohibited.

8. Training and Communication

All employees will be briefed on this policy prior & upon joining and periodically thereafter. This policy will be made available to all business partners, suppliers, and contractors.

9. Record Keeping

Accurate records of all gifts, hospitality, donations, and expenses must be maintained. No “off-book” accounts or false records are permitted.

10. Breach of Policy

Violations of this policy may result in disciplinary action, up to and including dismissal, contract termination, and legal proceedings.

11. Review

This policy will be reviewed annually and updated as required to ensure continued effectiveness and compliance with applicable laws, including the Malaysian Anti-Corruption Commission (MACC) Act 2009.

Important: Autorentic & EpicDewan platforms are owned by Tech Strongbox

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