ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

Hocatsu (M) Sdn Bhd is fully committed to observe the laws and regulations relating to anti-bribery or anti-corruption legislation which individuals are bound to comply with around the world and applying high standards of conduct and integrity in our business activities. We adopt a zero-tolerance approach to bribery and corruption in all its forms. Any employee who violates the rules or permits anyone to violate those rules is subject to appropriate disciplinary action, up to and including dismissal, and is subject to personal civil or criminal action.

This policy sets out Hocatsu (M) Sdn Bhd’s responsibilities in the objective of promoting an anti-corruption mindset and instilling honest and transparent practices among all employees, as well as providing an avenue for its employees and the public to lodge complaints of any corrupt practices within the company.

We strictly prohibit the followings:-

• The offering, the giving, the solicitation or the acceptance of any bribe as an inducement or reward including cash equivalents, gifts, entertainment, position or other services
• Abuse of office or position wherever they are situated and whether they are a public official in making decisions for purpose of self-interest
• The illegal or unethical way to gain any commercial, contractual or regulatory advantage
• To gain any personal advantage, pecuniary or otherwise for the individual or anyone connected with the individual

Everyone has a role to play in combating corruption whether it is to act responsibly or lead by example. It is our joint responsibility to create a conducive environment in which the values of honesty, integrity and transparency are upheld and by which our business can flourish.

WHISTLEBLOWING POLICY

1. POLICY STATEMENT

Hocatsu (M) Sdn Bhd is fully committed to the highest standard of openness, accountability, ethics and integrity in the conduct of its businesses and operations. An accountable and transparent workplace provides a mechanism for employees and members of the public to disclose any improper conduct in a responsible and appropriate manner.

2. OBJECTIVE OF THE POLICY

This policy is to provide an avenue for all employees and relevant stakeholders to disclose any improper conduct in accordance with the procedures as provided for under this policy and to provide protection for employees and members of the public who report such allegations.

3. SCOPE OF POLICY

This policy is designed to facilitate employees and members of the public to disclose any improper conduct (misconduct or criminal offence) through internal channel. Such misconduct or criminal offences include the followings:-
a) Fraud, theft, embezzlement, dishonesty;
b) Corruption / Bribery;
c) Abuse of Power;
d) Conflict of Interest;
e) Misuse of Company’s Property;
f) Non Compliance with Procedure

The above list is not exhaustive and includes any act or omissions, which if proven, will constitute an act of misconduct at workplace or any criminal offence under relevant legislations in force.

4. APPLICABILITY OF THE POLICY

Subject to the requirement of applicable local jurisdiction, this policy applies to all employees of Hocatsu (M) Sdn Bhd and members of the public, where relevant.

5. PROCEDURE IN MAKING A DISCLOSURE

Any employees or members of the public who have knowledge or is aware of any improper conduct committed within Hocatsu (M) Sdn Bhd is encouraged to make disclosure by following the procedures as stated:-

a. Reporting Channels

• Email to tblim@siahuat.com.sg
• In writing to Hocatsu (M) Sdn Bhd at
  Wisma Sia Huat No. 3A, Jalan 225, Seksyen 51A 46100 Petaling Jaya, Selangor
  Attention to: Mr Lim Thean Boon

b. Disclosure of Identity
In order to carry out an investigation, details and information on the concern made by the Whistleblower should be disclosed. The Whistleblower is required to disclose his/her personal details (which will be kept confidential).

• Name
• NRIC No:
• Contact Details: Office Contact / Mobile / Home

c. Scope of Reporting
Any improper conduct (misconduct or criminal offence) including but NOT limited to the followings:-

• Fraud, theft, embezzlement, dishonesty
• Corruption / Bribery
• Abuse of Power
• Conflict of Interest
• Misuse of Company’s Property
• Non Compliance with Procedure

d. Content of Disclosure
Any disclosure made herein should contain the following information:-

• Nature of improper conduct
• The date and location of the incidence
• The identity of the alleged wrongdoer
• Other relevant information; and
• Any supporting evidence if available

6. PROTECTION TO WHISTLEBLOWER

A Whistleblower will be accorded with protection under the Policy provided that the disclosure is made in good faith. Such protection is accorded even if the investigation later reveals that the Whistleblower is mistaken as to the facts and the rules and procedures involved.
The protection to the Whistleblower can be revoked under the following circumstances, among others:-

• The Whistleblower participated in the improper conduct
• The Whistleblower wilfully discloses a false statement
• The disclosure is made with malicious intent; or
• The disclosure is frivolous or vexatious.

7. ANONYMOUS WHISTLEBLOWER

Any anonymous disclosure will not be entertained. Any employee or member of the public who wishes to report improper conduct is required to disclose his identity to the Company in order for the Company to accord the necessary protection to him. However, the Company reserves its right to investigate into any anonymous disclosure.

8. NOTIFICATION

Upon the completion of the whistleblowing process and procedures, the whistleblower will be accorded the privilege to be notified on the outcome of the disclosure.