This Anti-Bribery and Corruption Policy (“this Policy”) has been developed as part of SYNERGY BIZ SOFTWARE DEVELOPMENT SDN. BHD, its affiliates and subsidiaries (individually and collectively, “we”, “us” or “our”)’s Anti-Corruption Management System which has been designed to align with Malaysian Anti-Corruption Commission Act 2009 (“MACCA 2009”), in particular, Section 17A thereof and other laws which are applicable to preventing bribery and/or corruption (“Relevant Laws”).


We have adopted a zero-tolerance approach against all forms of bribery and corruption. Full compliance to both the spirit and the letter of this Policy is mandatory.




The purpose of this Policy is to:


(a)       set out our responsibilities and of those working for or with us, in observing and upholding our position on bribery and corruption; and


(b)       provide information and guidance to those working for or with us on how to recognize and deal with bribery and corruption issues.




This Policy is applicable to our group of companies (including our parent company, representatives, subsidiaries, affiliates, related and/or associated companies), our business associates, contractors, agents and all of our employees, including permanent and temporary employees, senior management and the members of our board of directors (hereinafter collectively referred to as our “Personnel”).


Although this Policy is specifically written for our Personnel, we expect that all parties we engage to provide services for ourself or our nominee through our digital platform or otherwise (“Associated Persons”) will comply with this Policy as it may be applicable when providing such services.




1.         Bribery And Corruption


Bribery and corruption mean any action which would be considered as an offence of giving or receiving Gratification under the Relevant Laws, including but not limited to offering, giving, receiving or soliciting something of value in an attempt to illicitly influence the decisions or actions of a person who is in a position of trust within an organisation.


Bribery and corruption in all its forms as it relates to our activities are STRICTLY PROHIBITED. All Personnel and Associated Persons shall not therefore whether directly or indirectly, offer, give, receive or solicit any Gratification, in the attempt to illicitly influence the decisions or actions of a person in a position of trust within an organisation, either for our intended benefit or for the benefit of any person involved in the transaction.


The prohibition of bribery and corruption applies equally to all business dealings with private sector and government entities, and includes their directors, personnel, agents and other appointed representatives.


2.         Gratification


2.1.     Section 3 of the MACCA 2009 which provides for definition of “Gratification” is reproduced as follows:-


(a)       “money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;


(b)       any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;


(c)       any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;


(d)       any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;


(e)       any forbearance to demand any money or money's worth or valuable thing;


(f)        any other service or favour of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and


(g)       any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f)”.


2.2.     In this regard, all Personnel and Associated Persons shall adhere strictly to the following rules in respect of gifts and hospitality:-


(a)       not to give, agree to give, promise or offer Gratification with the expectation or hope that either us, himself or herself would be given a business advantage;


(b)       not to give, agree to give, promise or offer Gratification to any officer of the government or public body so that we will improperly be given an advantage or to expedite a routine procedure;   


(c)       not to give, agree to give, promise or offer Gratification which is or could reasonably be perceived to be against this Policy;


(d)       not to pay, offer or agree to pay from their personal bank account for Gratification as a means to circumvent this Policy;


(e)       not to induce our Personnel to indulge or get involved in any conduct prohibited by this Policy;


(f)        not to engage or get involved in any activity or conduct that is inconsistent with this Policy; and


(g)       not to solicit, receive or agree to receive Gratification of any kind to from any other person with the intention to obtain or retain business or any advantage in the conduct of business for us.


2.3.     In exceptional situation, our Personnel may be allowed to give Gratification provided the following principles are adhered to:-


(a)       the giving of the gift shall be disclosed to the immediate superior; and


(b)       the giving of the gift shall be made without intention to obtain or retain business or any advantage in the conduct of business for us.


3.         Donation And Sponsorships


We may make donation or offer sponsorships for charitable purposes to external parties. However, we prohibit the giving and receiving of donations and sponsorships to influence business decisions.


4.         Facilitation Payment


Facilitation Payment” means any unofficial payment made to any party to secure or to expedite a routine act of business. We adopt a strict policy of disallowing the use of Facilitation Payments in the business. All Personnel and Associated Persons shall decline or avoid any conduct or activity which may lead to the payment of any Facilities Payment.


In the event that any of the Personnel or Associated Persons is asked or needs to make payment on our behalf, the said Personnel or Associated Persons shall consider the purpose and intention of the payment before proceeding to make a decision whether or not to make such a payment. If a payment is made, a receipt, whenever applicable, must be obtained and be handed over the account department as soon as possible.


5.         Non-Conflict


Conflicts of interest arise in situations where there is personal interest that could be considered to have potential interference with objectivity in performing duties or exercising judgment on our behalf. All Associated Persons should avoid situations in which personal interest could conflict with their professional obligations or duties. All Personnel and Associated Persons must not use their position, official working hours, our resources and assets, or information available to them for personal gain or to our disadvantage.


6.         Other Responsibilities


6.1.     All Personnel are strictly required to carry out the following responsibilities and obligations relating to the Company’s Anti-Corruption Management System:-


(a)       be familiar with applicable requirements and directives of this Policy and communicate the same to the subordinates;


(b)       attend any training programme as we require held under the Company’s Anti-Corruption Management System;


(c)       be alert to any indication or evidence of possible violations of this Policy;


(d)       always raise suspicious transactions and other “red flags” (indicators of bribery or corruption) to the immediate superiors for guidance on the next course of action;


(e)       promptly reply violations or suspected violations through the channel as provided herein;


(f)        not to offer, promise or make any attempt at dishonestly influencing the person’s decision by directly or indirectly offer or make promise of corrupt payments, in cash or in kind;


(g)       not to involve in any discussions regarding business or employment opportunities, for your own personal benefit or for the benefit of the external party; and


(h)       not to abuse the decision making and other delegated powers given by the top management, in order to illicitly secure an outcome which would be to the commercial advantages for us or yourself.




If anyone becomes aware of any actual or suspected breach of this Policy, you must, as soon as practicable, report your concerns to the designated whistleblowing channel as stated below:-


[email protected]



All the reports made through the whistleblowing channel above, either anonymously or otherwise, shall be made in good faith in a timely manner and without incurring fear of reprisal regardless of the outcome of any investigation.




Our Personnel operating in areas that are perceived as high risk will receive regular and relevant training on how to implement and adhere to our Anti-Corruption Management System. The attendance to all the training programme being held is COMPULSORY.


Our zero-tolerance approach against all forms of bribery and corruption must be communicated to all suppliers, contractors, agents, business and other partners at the outset of our relationship with them and as appropriate thereafter.




ALL OUR PERSONNEL shall be responsible in monitoring the implementation of this Policy and ensure that the Policy is adhered to.


We are committed to keep no accounts “off the record” to ensure the transparency of all business dealings. We are committed to conduct internal audit from time to time.


We are committed to reviewing and amending this Policy on a periodical basis to ensure effectiveness of this Policy.




Any of our Personnel who contravenes the terms of this Policy or the applicable laws may be subject to internal disciplinary action, which may include dismissal or termination of employment.


In the event that any of the Associated Persons fails to comply with all the terms of this Policy or the applicable law, we reserve our rights to terminate any or all contract(s) we entered into where the said Associated Persons is (or purported to be) privy thereto.


We reserve our right to lodge a report of the conduct of the person to the relevant authorities or bodies, including the Malaysian Anti-Corruption Commission.




We would carry out regular assessment of this Policy to ensure its scope, policies, procedures and controls are in line with the bribery and corruption related risks that we might be exposed to. Therefore, we reserve our rights to amend or modify this Policy at any time as we deem appropriate, with or without notice.