ANTI-BRIBERY AND CORRUPTION POLICY

1. INTRODUCTION
   1. This Anti-Bribery and Corruption Policy is issued to provide Jetson Group’s Employees, and any Third Parties that are currently engaged or to be engaged by Jetson Group with basic guidelines on how to deal with improper solicitation, bribery and other corrupt activities and issues that may arise in the course of business.
      Kumpulan Jetson Berhad and all its subsidiaries and associate companies are collectively referred to as “the Jetson Group” or “the Group”.
   2. This Anti-Bribery and Corruption Policy was prepared in line with the requirement set forth in the Guidelines on Adequate Procedures issued on 10 December 2018 by the Prime Minister’s Office pursuant to Section 17A (5) of the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act 2009”). However, this is not a definitive answer and in cases where there is a conflict between mandatory laws and the principles contained in this Anti-Bribery and Corruption Policy, the law shall prevail.
   3. This Anti-Bribery and Corruption Policy applies in addition to, and not to the exclusion of, Jetson Group’s other policies and procedures including its Code of Ethics & Conduct and Whistleblower Policy.
   4. This Anti-Bribery and Corruption Policy has been approved by the Board at its meeting held on 29 April 2020 and will be effective from 1 June 2020.
   5. All recipients of this Anti-Bribery and Corruption Policy are expected to read and to adhere to this Anti-Bribery and Corruption Policy. If there is any query on the Anti-Bribery and Corruption Policy, please consult Group Human Resource & Administration Department.
      
      
2. PURPOSE
   1. The purpose of this Anti-Bribery and Corruption Policy is to:
      1. set out Jetson Group’s responsibility, and those working for it, to comply with laws against bribery and corruption;
      2. provides information and guidance to those working for Jetson Group on how to recognize and deal with corruption and bribery issues
         
         
3. APPLICABILITY
   1. The compliance of this Anti-Bribery and Corruption Policy is mandatory and is applicable to:
      1. All business entities over which Jetson Group has effectively control;
      2. All individuals working for Jetson Group wherever located, at all levels and grades including directors, senior management and employees (whether full time, probationary, contract or temporary) (collectively “Employees”); and
      3. All Third Parties that are currently engaged by Jetson Group or to be engaged by Jetson Group in the future (collectively “Associated Third Parties”)

         In this Policy, “Third Party(ies)” means any individual or organization, who/ which come into contact with Jetson Group or transacts with Jetson Group and also includes actual and potential clients, suppliers, vendors, business contacts, consultants, intermediaries, representatives, subcontractors, industry associations, investors, research analysts, agents, advisers, joint ventures and government & public bodies (including their advisers, representatives and officials).

   2. Joint-venture companies in which Jetson Group does or does not has effective control interest and associated companies are encouraged to adopt these or similar principles;
      
      
4. DEFINITIONS
   

   Bribery	Offering, giving, receiving or soliciting something of value in an attempt to illicitly influence the decisions or actions of a person a position of trust within an organization
   Conflict of Interest	When the Employee is or may be in a position to take advantage of his/her role by using confidential information, assets and other resources for his/ her personal gain or for the advantage of his Closely Related Person. A “Closely Related Person” is someone you are related to, have a personal friendship with, or anyone living in the same household as you.
   Corruption	The misuse of a public office or power for private gain or the misuse of private power in relation to business outside the realm of government.
   Donation	A Donation is a charitable gift of money, goods or services given to a group or organization without the anticipation of benefit in return.
   Facilitation Payment	A “Facilitation Payment” includes any payment or advantage made to an individual in control of a process or decision in order to secure or expedite a routine or administrative duty or function. It is illegal under the MACC Act 2009 as it falls within the meaning of gratification of bribery.
   Gifts	A gift comprises of cash money, free airfares, shares, travelling facilities, club membership, any form of commission, jewelry, and any item of high value.
   Hospitality	The friendly reception and entertainment of guests. Hospitality may range from exorbitant restaurant meals to sponsored travel and accommodation.
   Kickbacks	Payment of any portion of a contract made to employees of another contracting party or the utilization of other techniques, such as subcontracts, purchase orders or consulting agreements to channel payment to Public Officials, political parties, party officials or political candidates, to employees of another contracting party, or their relatives or business associates.
   Sponsorship	Sponsorship is a contribution in money, in kind, or in services to support an event, activity, person or organization in return for certain and specified benefits or value for Jetson Group’s business activities.

5. IN PRINCIPLES
   1. Jetson Group take a zero-tolerance approach against all forms of bribery and corruption, whether direct or indirect, and no Employees or Associated Third Parties should commit, be a party to or be involved in any bribery or corruption.
   2. Jetson Group is committed to adhering to best and acceptable practice in corporate governance and observing the highest standards of integrity and behavior in all its relationship and business dealing wherever it operates and to implement and enforce effective system to counter bribery.
   3. Jetson Group will uphold all relevant anti-bribery and corruption laws, which include compliance with the Malaysian Anti-Corruption Commission Act 2009 (Act 694) and the Malaysian Anti-Corruption Commission (Amendment) Act 2018 and any of its amendments or re-enactments that may be made by the relevant authority from time to time.
   4. Jetson Group will undertake a bribery and corruption risk assessment across our business when appropriate and ensure that it has adequate procedures in place to address those risks.
      
      
6. RESPONSIBILITIES
   1. The Board of Directors is collectively responsible to provide oversight of this Anti-Bribery and Corruption Policy and the Chief Executive Officer and the Management are responsible for ensuring the compliance with this policy.
   2. All Employees, and any Associated Third Parties have a duty to read, understand and comply with this Anti-Bribery and Corruption Policy. All Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy, and reporting of bribery and other forms of violation as early as possible via the channel outlined in Jetson Group’s Whistleblowing Policy.
   3. Bribery and corruption are criminal offences and carry very serious sanctions. An Employee will be personally liable whether he or she pays a bribe himself or herself or whether he or she authorizes, assists or conspires with someone else to violate the anti-corruption or anti-bribery law. Punishment for violating the law are against him/her as an individual and may include imprisonment, probation, mandated community service and monetary fines and others which will not be paid by Jetson Group.
   4. Besides, Employees and Third Parties working for Jetson Group should also aware that violation of any of the Policy’s provisions may result in disciplinary action, including dismissal or termination of contract. Jetson reserves its right to terminate its contractual relationship with those who breach this Policy.
      
      
7. NO BRIBES POLICY
   1. Jetson Group strictly prohibits bribery and corruption in any form, whether direct or indirect. No Employees and Business Associates should commit, be a party to or be involved in:
   2. Give, Promise to Give, or Offer a Bribe; All Employees and Associated Third Parties shall not directly, or indirectly through third party, give, offer or promise any financial or other advantage to recipient (public official/ private party or their family member) to improperly obtain or retain business or to obtain any other business advantages.
   3. Request, Agree to Receive or Accept a Bribe All Employees and Associated Third Parties shall not directly, or indirectly through third party, request, agree to receive or accept a financial or other advantage intending to induce or reward a breach of trust, impartiality or good faith.
   4. No Employee or Associated Third Parties will suffer demotion, penalty or other adverse consequences in retaliation for refusing to pay or receive bribes or participate in other illicit behavior.
      
      
8. CONFLICT OF INTEREST
   1. A Conflict of Interest does not necessarily involve improper or corrupt behavior. Nevertheless, it may give rise to risk of bribery i.e. being exposed to solicitation or extortion as result of failing to inform management about a Conflict of Interest or acting improperly in favor of another interest.
   2. As such, all Employees are required to make a declaration and withdraw from taking any action or participating in any decision-making process in matters where they have or potentially have a conflict of interest.
   3. Associated Third Parties are required to declare their interest prior to participating, onboarding or when there is a change of circumstances.
   4. Jetson Group reserves the right to discontinue involvement of any of the Employees or Associated Third Parties in such dealing if they perceive any conflict of interest.
      
      
9. FACILITATION PAYMENT AND KICKBACKS
   1. Jetson Group strictly prohibit any receiving, giving and promising of Facilitation Payments unless there is an imminent threat or danger to an employee, in such circumstances, a payment may be made but it must be immediately reported to Group Human Resource and Administration Department.
   2. Likewise, all Employees and Associated Third Parties must avoid any activity that might lead to, or suggest that a Kickback will be made or accepted by Jetson Group.
      
      
10. GIFTS AND HOSPITALITY
    1. Jetson Group does not prohibit normal and appropriate hospitality to or from third parties. However, any gifts and hospitality given or received must be in compliance with law and must not violate this Anti-Bribery and Corruption Policy and Code of Ethics & Conduct. All forms, manifestations and appearances of bribery are opposed.
    2. Employees are permitted to offer, give and receive reasonable and customary gifts and hospitality, but only if all the following conditions are:
       1. It is not done with the intention to obtain an improper benefit;
       2. It is appropriate professional nature and be both reasonable and appropriate in terms of value and frequency;
       3. It is not cash (or cash-equivalents such as gift vouchers or gift cards), except for giving / receiving of very nominal value amount (RM10.00 or less) in accordance with local custom such as ang pow at Chinese New Year;
       4. All requisite approvals are obtained.
    3. All gifts given to Employees and Associated Third Parties must be recorded in Gift Register maintained by Group Human Resources & Administration Department; and all aforesaid gifts must be sent to Group Human Resource & Administration Department while waiting for the management’s decision of the gift treatment.
    4. For further details, please refer to the Section 3.8 of Jetson’s Code of Ethics and Conduct. In the event of inconsistency, this Policy shall prevail.
       
       
11. DONATIONS AND SPONSORSHIP
    1. All Donations and Sponsorship provided by the Jetson Group must be compatible with Jetson Group’s business activities, reflect Jetson Group’s commitment to operating in an ethical manner and must not to be used as a subterfuge for bribery or illegal payments.
    2. No donation or offer of sponsorship shall be made or offered without the prior approval of the duly authorized executive of the Jetson Group.
       Political Contributions
    3. Contribution to political parties whether directly or indirectly, is strictly prohibited.
    4. Jetson Group does recognize the rights of Employees or Associated Third Parties to use their own funds to make political donations and/or participate in political activities, provided that those activities are not linked in any way to the role that they carry out for the Group. Jetson Group will not make any reimbursement for the Political Contributions made by Employees or the Associated Third Parties.
       Charitable Donations and Sponsorships
    5. Charitable Donations or Sponsorships by Jetson Group may only be made where:
       1. it is made in compliance with applicable laws;
       2. it is not made to secure an improper benefit;
       3. it is made to registered charities with a valid charitable purpose; and
       4. all requisite approval is obtained
    6. All requests for donations or sponsorship must accompanied by written evidence of the proposed donations or sponsorships and to be carried out directly with the end entity/ beneficiary, without any intermediaries.
    7. Risk based due diligence to be conducted, as appropriate, on the recipients of any charitable contributions or sponsorships. This is necessary to prevent contributing to charitable organizations which may be engaged in money laundering or other criminal activities.
       
       
12. BUSINESS RELATIONSHIPS
    1. Jetson Group expects all Associated Third Parties to review this Anti-Bribery and Corruption Policy and to implement and share the Group’s values and ethical standards. Where necessary, they shall be subjected to due diligence process from time to time to assess their integrity and ability to comply with the Anti-Bribery and Corruption Policy.
    2. Jetson Group reserves the right to terminate any pending negotiations, tender, purchase order or contract that does not comply with the provisions set forth in this Anti-Bribery and Corruption Policy. Jetson Group will not be accountable or liable for any losses, claims or crime, actions arising or due to such terminated transaction.
       
       
13. INTERNAL CONTROLS AND RECORD KEEPING
    1. Jetson Group is committed to establish and maintain an effective internal control system to counter bribery and corruption. These internal controls comprise financial and organizational checks and balances over Jetson Group’s accounting and record keeping practice and other business processes related to its Anti-Bribery and Corruption Policy and procedures. The system will be regularly reviewed and audited to ensure that it remains effective. 13.2 Jetson Group shall at all times maintain accurate books and records that properly and fairly reflect all financial transactions. No “off-the-book” accounts shall be kept to facilitate or conceal improper payments. 13.3 Jetson Group must keep financial records for a minimum period of 7 years and shall make available all the relevant records for inspection and shall cooperate appropriately with relevant auditors or authorities in all bribery and corruption investigations.
       
       
14. CONFIDENTIALITY AND PROTECTION
    1. Jetson Group is committed to ensuring that all disclosures are protected with confidentiality and no one shall suffer any detrimental treatment as result of reporting concerns under this Anti-Bribery and Corruption Policy.
       
       
15. TRAINING AND COMMUNICATION
    1. This Anti-Bribery and Corruption Policy would be circulated to all Employees and Associated Third Parties acting on behalf on annual basis and as and when the amendment is made.
    2. Each new Employee/ new Associated Third Parties of Jetson Group should, during their induction program/ upon the engagement, be required to read and signed the policy.
    3. Jetson Group’s zero-tolerance to bribery must be communicated to all suppliers, contractors and business partners at the outset of Jetson Group’s business relationship with them and as appropriate thereafter.
    4. To ensure thorough understanding of the Anti-Bribery and Corruption Policy, training and awareness sessions on this Policy will be provided as required and to the level appropriate to respective party.
       
       
16. MONITORING AND REVIEW
    1. Jetson Group will monitor the effectiveness and review the implementation of this Anti-Bribery and Corruption Policy regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made soonest possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
       
       
17. REVIEW OF THE ANTI-BRIBERY AND CORRUPTION POLICY
    1. The Board will monitor compliance with the Policy and review the Anti-Bribery and Corruption Policy regularly to ensure that it continues to remain relevant and appropriate.
       
       
18. RELATED POLICIES AND PROCEDURES
    1. This Anti-Bribery and Corruption Policy should be read in conjunction with Jetson Group’s other policy documents including the following:
       1. Code of Ethics & Conduct
       2. Whistleblowing Policy