Anti-Bribery and Corruption Policy

1.0 PURPOSE

The purpose of this Policy is to provide guidance to Nazmi Zaini Chambers’ partners, employees and any third party who performs services for and on behalf of Nazmi Zaini Chambers (“Business Associates”) in understanding their roles and responsibilities in order to identify and deal with bribery and corruption issues.

2.0 SCOPE

This policy applies to all partners, employees including temporary, contract staff or interns (“Employees“) and Business Associates of Nazmi Zaini Chambers. Although this Policy is specifically written for the Employees of Nazmi Zaini Chambers, Nazmi Zaini Chambers expects that all parties engaged by Nazmi Zaini Chambers or performing work or services for or on behalf of Nazmi Zaini Chambers will comply with it in relevant part when performing such work or services.

3.0 POLICY STATEMENT

Nazmi Zaini Chambers is committed in conducting its business in an ethical, professional and honest manner. Nazmi Zaini Chambers has zero tolerance to corruption and bribery and will adhere to the antibribery and corruption laws in Malaysia.

4.0 THE POLICY

4.1 Bribes

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. All partners, Employees and Business Associates must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor).

4.2 Facilitation Payments

Facilitation payments are strongly prohibited in Nazmi Zaini Chambers.

4.3 Public Officials

When dealing with government officials or related associated persons, due care must be exercised at all times to ensure any giving or receiving of kickbacks or gratuities to/from government officials whether directly or indirectly are always avoided.

4.4 Giving and Accepting of Gifts & Hospitality

All partners and Employees of Nazmi Zaini Chambers are prohibited from offering, soliciting or receiving any gifts or hospitality in any form, to or from current or potential clients, vendors, agents and business partners, either directly or indirectly which may influence the partner’s or Employee’s judgment in a decision-making process or put the Employee in a position of conflict.

4.5 Donations And Sponsorships

Nazmi Zaini Chambers prohibits any donations and sponsorships to any political party, political party official or candidate in the name of Nazmi Zaini Chambers. Donations should not give rise to the appearance of impropriety or a violation of any local country legal requirements including as a channel for money laundering, terrorism financing or other criminal activities. Due diligence must be conducted on recipients of donations to ascertain that they are of reputable standing. All donations and sponsorships must be reviewed and approved by the authorized personnel.

4.6 Recruitment of Employees

Nazmi Zaini Chambers practices equal job opportunities. Recruitments are based on merits after a proper due diligence check has been conducted. A prospective personnel should not be offered employment in order to obtain or retain an advantage in business.

4.7 Conflict of Interest

All partners and Employees must ensure that their personal affairs will not give rise to any conflict of interest or appear to be conflicting with Nazmi Zaini Chambers’ interests. Partners and Employees must obtain written approval of their respective heads before undertaking activities which may give rise to conflict of interest. All partners and Employees shall declare their conflict of interest, both on a scheduled basis, and ad hoc as soon as they arise.

4.8 Training and Awareness

Nazmi Zaini Chambers shall conduct training on how to implement and adhere to this policy on all existing employees and new joiners. Regular updates will be shared with the Employees whenever there is a change in the legislation. It is the Employees’ responsibility to ensure that they attend all trainings provided by Nazmi Zaini Chambers.

4.9 Raising Concerns (Whistleblowing)

Partners, Employees and business associates are encouraged to raise their concerns when they become aware of any actual or suspected breach of this Policy to our whistleblowing channel: whistleblower@nzchambers.com. All reports will be treated with the utmost confidentiality and the whistleblower may report anonymously. When required, Nazmi Zaini Chambers shall report details of the corruption and bribery incidents to the relevant authorities. Provided that the disclosure was made in good
faith, Nazmi Zaini Chambers prohibits retaliation of any kind against any partners, Employees and Business Associates for reporting on actual or suspected violation of this Policy.

4.10 Compliance and Review of the Policy

The management of Nazmi Zaini Chambers is responsible in implementing and monitoring the compliance with this Policy. All Employees are responsible to keep themselves abreast with Nazmi Zaini Chambers’ Employee Handbook as well as its latest policies and processes, in particular, this Policy and ensure that the highest standards of compliance are followed. Failure to comply with this Policy may lead to Employees being subject to disciplinary action, up to and including dismissal. This Policy will be reviewed at least once every three years to ensure its relevancy and continued compliance with the prevailing law.