Anti-Bribery and Corruption Framework

INTRODUCTION

With integrity as one of DBOS' core values, DBOS will not tolerate any acts contrary to this value. DBOS firmly believes in acting professionally, fairly and with integrity in all its business dealings and relationships.

The objective of this ABC policy as adopted by DBOS is to show to our stakeholders and partners that DBOS has adequate procedures in place in compliance with all current anti-bribery and corruption legislations in force. This will also serve as a key statutory defence for DBOS pertaining to corporate liability provisions.

DBOS CORRUPTION-FREE PLEDGE

In support of the Malaysian Anti-Corruption Commission's Corruption-Free Pledge initiatives, DBOS has voluntarily undertaken the action to make it mandatory for DBOS' leadership and employees in an individual capacity to pledge and make a unilateral declaration against corrupt practices and further to hold each of them accountable and responsible for carrying out their duties and to hinder them from engaging in any corruption misconduct throughout their tenure with DBOS.

ANTI-BRIBERY AND CORRUPTION POLICY ("ABC POLICY")

1. ABC POLICY STATEMENT
   In furtherance to DBOS' anti-corruption approach as outlined in the ABC Policy, DBOS clearly describes our zero-tolerance policy to any form of bribery and corruption.
2. SCOPE OF THE ABC POLICY
   The ABC Policy applies:
   1. To all Directors, Senior Management, Employees and Agent(s) having any dealings with DBOS (collectively referred to as “DBOS' Representative).
   2. It is also expected that all the agent(s) who performs works and/or services for or on behalf of DBOS will comply with the relevant parts (where applicable) of the ABC Policy when performing such works or services.
3. KEY PRINCIPLES OF THE ABC POLICY
   1. APPOINTMENT AND RECRUITMENT OF DIRECTORS AND EMPLOYEES
      Proper background checks and assessments shall be conducted as part of DBOS' commitment on conducting due diligence as spelt out in DBOS' Fit & Proper Criteria Policy and Employee Handbook respectively, in order to ensure that the potential candidate for appointment or recruitment has not been implicated or convicted for any offence related to corruption.
   2. PROCUREMENT PRACTICE AND ENGAGEMENT OF AGENT(S)
      DBOS expects that all agent(s) acting for or on its behalf, to share DBOS' values and ethical standards, as their actions can implicate DBOS legally and tarnish DBOS' reputation. Therefore, upon any potential engagement of any agent(s), DBOS is obligated to conduct appropriate due diligence on the agent(s) to understand the business and background of the prospective agent(s) before entering into any binding arrangement with them. This is part of the safeguard measures that DBOS adopts when dealing with the agent(s) in ensuring that the said agents subscribed to the acceptable standard of integrity in the conduct of their business.
      • DBOS' Procurement Practice Statement
        DBOS' procurement processes and strategies have been established to ensure that the services and goods DBOS acquired are the result of transparent, objective, time and cost-effective decision-making inclusive of good governance and risk management considerations as embedded in DBOS' Vendor Code of Conduct.
      • DBOS' Vendor Code of Conduct
      • DBOS' Purchase Order Terms & Conditions
   3. GIFT AND HOSPITALITY
      Both Directors and Employees of DBOS are expected to demonstrate the highest level of professional conduct when conducting business on behalf of DBOS. DBOS' Gifts & Hospitality Policy and Procedure sets out when certain gifts and hospitality must be refused, strict situations when such are exempted and also when it is appropriate for DBOS' Representative and all others as defined in the Gifts & Hospitality Policy and Procedure, on the receiving, providing and registration of the said gifts and hospitality.
      • DBOS' Gifts and Hospitality Policy
   4. POLITICAL CONTRIBUTION AND DONATIONS
      DBOS DOES NOT make or offer any form of political Contributions and donations to political parties and their agent(s).
   5. CHARITABLE CONTRIBUTIONS AND SPONSORSHIP
      In general, NO CHARITABLE CONTRIBUTIONS AND SPONSORSHIP (which include but are not limited to general donations) should be made because these could be construed as improperly influencing another party with whom DBOS has a business relationship.
      
      However, as part of DBOS commitment to corporate social responsibility and sustainable development, DBOS will consider to providing such assistance in appropriate circumstances and in an appropriate manner which is subject to the approval of DBOS' Chief Executive Officer / Board in accordance with DBOS' approved limit of approval. Any request must be carefully examined for legitimacy and not be made to improperly influence a business outcome.
      
      Before committing to a corporate social responsibility activity, DBOS must first conduct proper due diligence to ensure that the requests are legitimate and that the charitable contributions or sponsorship or general donations are made or offered in accordance with DBOS' approved mandate.
   6. FACILATION PAYMENT
      DBOS adopts a STRICT POLICY OF DISALLOWING the use of facilitation payments in its business. DBOS' employees shall decline to make the payment and report appropriately on an immediate basis when they encounter any requests for a facilitation payment.
   7. CONFLICT OF INTEREST
      Conflicts of interest arise in situations where there is a personal interest that could be considered to have potential interference with the objectivity in performing duties or exercising judgment on behalf of DBOS.
      
      DBOS' Representatives should avoid situations in which personal interest could conflict with their professional obligations or duties. DBOS' Representatives must not use their position, official working hours, DBOS' resources and assets, or any information available to them for personal gain or to DBOS' disadvantage.
   8. RECORD KEEPING
      Through DBOS' Finance Department, DBOS maintains detailed and accurate financial records and has appropriate internal controls in place to act as evidence for all payments made by DBOS. DBOS will ensure that these records are prepared and retained and are accessible during audits by statutory auditors as mandated by laws.
   9. ANTI-BRIBERY AND CORRUPTION COMPLIANCE FUNCTION
      DBOS has established an Integrity & Governance Unit (“IGU”) function and this function is responsible for monitoring the effectiveness of the ABC policy and will review the implementation of it on a regular basis.
   10. INDEPENDENT INTERNAL AUDIT
       An independent review shall be carried out by DBOS' Internal Audit Department (“IAD”) to assess the performance, efficiency and effectiveness of the ABC Policy.
   11. RISK ASSESSMENT
       An assessment of the corruption risk shall be carried out by IGU as part of its risk assessment as per methodology that IGU adopts based on standards guided by MACC and/or UNIONS from time-to-time.
       
       The results of the risk assessments are used to assess the risks which DBOS may face in its business activities and to establish appropriate DBOS’ policies and procedures to reduce those risks to an acceptable level.
       
       IGU shall conduct a comprehensive Corruption Risk Management to identify and assess corruption risk every three (3) years, with intermittent assessment conducted when there is a change in law or circumstance.
   12. SANCTIONS FOR NON-COMPLIANCE
       1. Non-compliance as identified by IAD shall be accordingly reported to the Board's BARCOM in a timely manner.
       2. Any conduct which is not in accordance to the principles set out in this ABC policy, will be dealt as serious matters and severe penalties may be applied in the event of non-compliance to this ABC policy.
       3. For DBOS employees, non-compliance may lead to disciplinary action, up to and including termination of employment as stipulated in DBOS' Employee Handbook.
       4. For agent(s), non-compliance may be treated as a breach of contract that involves penalties including suspension or termination of contract. Further legal action may also be taken in the event that DBOS' interests have been harmed by the results of non-compliance by agent(s).
       5. Adherence to the ABC Policy is critical to the smooth running of DBOS' business or operations and for the common good of DBOS and all concerned.
   13. REPORTING CHANNEL
       DBOS has established an accessible reporting channel for internal and external parties to raise concerns with regard to malpractices of DBOS' policies and procedures as established in a manner guided by DBOS' Complaint Management Policy.
       • DBOS' Complaint Management Policy
   14. TRAINING AND AWARENESS
       Effective communication, training and awareness on Anti-Bribery and Corruption programme are and shall be on an ongoing basis conducted for Directors, employees and agent(s) of DBOS, inclusive of any new hire / engagement. As part of such commitment, DBOS will provide training on the ABC policy as part of the induction process for all new employees and as and when there are new updates to applicable laws or practices related to anti-corruption.
   15. POLICY OWNER
       The ABC policy is owned by DBOS' IGU. Any feedback or enquiries regarding the provisions of this ABC policy should be directed to the DBOS' IGU.