Anti-Bribery and Anti-Corruption Policy

POLICY STATEMENT

At ECI COPIER SDN BHD, we take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings, undertakings and relationships wherever we participate whether in any manner, as a stakeholder or otherwise.

ECI COPIER SDN BHD reiterates a zero-tolerance approach against all forms of bribery and corruption and is committed to compliance with all applicable laws in relation to anti-bribery and corruption in Malaysia, in particular the Malaysian Anti-Corruption Commission Act 2009 (“the MACC Act 2009”).

This policy sets out the minimum requirements, roles and responsibilities for combating bribery and corruption as well as avoiding the precarious situation of conflict of interest to the detriment of the stakeholders.

DEFINITIONS

“Associated Persons” means personnels such as associates, partners, staffs, directors of ECI COPIER SDN BHD including permanent, temporary, contractual personnel and entities and such other third parties engaged by ECI COPIER SDN BHD to perform work or services for or on behalf of ECI COPIER SDN BHD.

 “Bribery” means any offering, demanding, accepting, transferring, lobbying or soliciting a gainful advantage for one party, in order to improperly and inappropriately induce, influence, acquire or reward the performance of an act or refrain or withholding of an act, whether in a direct or indirect manner for any financial or other improper reward, given directly or through an intermediary.

 “Conflict of Interest” means circumstances whereby any entity or stakeholder is involved in several competing duty, relationships or objectives that are contradictory with one another’s interest under such circumstances.

 “Corruption” means abuse of power for personal individual enrichment, or the exploitation of one’s position to assist others, towards improperly and dishonestly enriching themselves whether directly or indirectly.

“Extortion” means the demanding of a gratification, including payments or other benefits, whether or not with a threat.

 “Facilitation payment” means any unlawful payment or gratifications made and performed in return for an act in which the paymaster is legally entitled to receive in the first instance itself.

 “Gifts” means any form of goods, assistance, services, which may be of monetary value or otherwise but essentially valuable to the person receiving it.

“Hospitality” means providing any manner of travel, transportation, lodging, as well as entertainment for the comfort of any individual(s).

 “Kickback” means pre-agreed bribery in which a fee is paid to the bribe-taker in exchange for any act or services to be provided.

“Staff” means partners, employees, directors, including temporary, contract staff or interns.

“Whistleblower” means is any individual of an entity who reports potential improper infringement that has happened within the same entity.

APPLICATION

This Anti-Bribery and Anti-Corruption Policy applies to all partners, staffs, entities, directors, affiliates and associates of ECI COPIER SDN BHD, in any capacity whether temporary, permanent or on contract. All parties engaged by ECI COPIER SDN BHD shall endeavour to comply with this Policy herein.

ANTI-BRIBERY AND ANTI-CORRUPTION

Associated Persons are not allowed by ECI COPIER SDN BHD to pay, offer or accept any bribe in any manner. Associated Persons are strictly not allowed to:

• Offer, pay or give anything of value, whether monetary or otherwise, to any entity in order to specifically obtain business or anything advantageous to ECI COPIER SDN BHD;
• Create advantage in any manner deemed by law to be inconsistent and wrongful or unlawful abuse of official position to acquire benefit or personal gain;
• Act illegally including bribes, blackmail, inducements, other rewards or similar improper actions for illegal, unethical and violation of any rules in place; and
• Suggest, give, receive or lobby, directly or indirectly, anything of value, whether monetary or otherwise to influence the decision of other party or stakeholder.

FACILITATION, EXTORTION AND KICKBACKS

ECI COPIER SDN BHD strictly prohibits and does not condone any accepting or giving, in any manner and whether directly or indirectly, any Facilitation and Extortion payments, kickbacks or similar arrangements which may be in the form of any gratification with the intent to affect the receivers in their decisions for or against the stakeholders.

GIFTS, HOSPITALITY & ENTERTAINMENT

All Associated Persons shall never request, accept, propose or provide such Gifts, entertainment and/or Hospitality with the intention to induce, support or reward improper act or refrain from certain act in connection with any commercial undertaking involving ECI COPIER SDN BHD.

All giving or receiving of Gifts, Hospitality and sponsored travel must be disclosed and reported to acquire necessary approvals from immediate superior. As a guiding principle, all Associated Persons should exercise prudent judgment in line with acceptable business practice in offering or receiving the above-mentioned. 

Subject to above disclosure and reporting, this Policy does not forbid offering or receiving any Gifts, Hospitality, entertainment or sponsored travel so long as they are appropriate and would not be perceived to have any improper influence on any stakeholders, consistent with acceptable business practice.

CONFLICT OF INTEREST

Conflicts of interest happens when an individual or entity, is entangled in several competing interests, one of which could possibly corrupt, perceived or otherwise, the underlying motivation for a specific decision and act in another.

ECI COPIER SDN BHD strive to upholds the highest standards of business practice and corporate integrity. We strive to ensure that any other conflicts of interest are disclosed, prevented and managed without interfering with the duties and responsibilities associated with ECI COPIER SDN BHD.

POLITICAL DONATIONS, SPONSORSHIPS & CHARITABLE CONTRIBUTIONS

Any donations, sponsorships and charitable contributions in any nature by ECI COPIER SDN BHD will be be done in a transparent manner primarily to fulfil corporate social and moral responsibility, benefitting the society at large. It should never be performed in exchange for any commercial advantage to ECI COPIER SDN BHD. Any requests for political donations shall be brought to the attention of the board of directors immediately.

WHISTLEBLOWING

If any Associated Persons become aware of any possible infringement of this Policy, they may report it for further investigation by ECI COPIER SDN BHD at the dedicated whistleblowing channel at eci@abc.com. All reporting are strictly confidential. All report are to be attended by a panel of independent members of the company.

POLICY REVIEW AND CLARIFICATION

ECI COPIER SDN BHD reserves the right to amend, review, modify or update this Policy at any time, without further notice. All clarifications in regards to any of the Policy herein is welcomed and can be addressed to us at eci@abc.com.

ECI COPIER SDN BHD

(Last updated in October, 2025)