At AutoWealth Malaysia (“AutoWealth”), we are steadfast in our commitment to conducting business with the highest standards of integrity, transparency, and ethical conduct. We adopt a zero-tolerance approach toward any form of bribery and corruption, whether direct or indirect, across all levels of our operations. This policy extends beyond mere compliance with local and international anti-corruption laws; it reflects our deeper commitment to ethical business practices that foster long-term, sustainable relationships with clients, partners, and communities.

AutoWealth Malaysia prohibits all forms of corrupt activities, including the offering, giving, receiving, or soliciting of any advantage, whether in the form of monetary or non-monetary benefits, to improperly influence business decisions or gain unfair advantages. This applies to all employees, directors, contractors, suppliers, agents, and any third parties acting on behalf of AutoWealth Malaysia (“Associated Persons”).

AutoWealth will not engage in or condone bribery, facilitation payments, or any corrupt practices under any circumstances. We expect every individual and entity connected with or on behalf of AutoWealth to act in a manner that preserves our reputation for integrity and responsible business practices.This Policy adheres to the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act 2009”) and is guided by the Guidelines Policy on Adequate Procedures issued pursuant to section 17A (5) of the MACC Act 2009.

2. Purpose and Scope

2.1 This policy applies to all operations and business activities carried out by AutoWealth Malaysia. It extends to every employee, officer, director, and any Associated Person acting on behalf of AutoWealth, including suppliers, consultants, contractors, and partners.

2.2 The overarching key principles are outlined in the Guidelines on Adequate Procedures pursuant to Subsection (5) of Section 17A under the Malaysian Anti-Corruption Commission Act 2009, issued by the Prime Minister’s Department. These principles guide the implementation of this policy:

1. Top-level commitment
2. Risk assessment
3. Undertake control measures
4. Systematic review, monitoring, and enforcement
5. Training and communication.

2.3 AutoWealth’s business operations, whether direct or indirect, must be conducted in line with the following standards:

1. Promote transparency, ethics, integrity.
2. Documented with appropriate business rationale
3. Authorised by the Senior Management at appropriate level
4. Ensure compliance with the laws of every jurisdiction where AutoWealth operates.
5. Provide clear guidance on acceptable conduct.

3. Definitions

1. Bribery: The act of offering, promising, giving, or accepting any financial or other advantage with the intention of influencing a person in the performance of their duty or to secure improper business advantages.
2. Corruption: The abuse of power for private gain.
3. Gratification: Any form of reward or benefit, whether monetary or non-monetary, such as gifts, loans, services, or favours, intended to influence the recipient improperly.
4. Facilitation Payments: Small payments made to expedite routine government actions. AutoWealth prohibits any form of facilitation payments.
5. Associated Persons: Any third-party individual or organisation that performs services for or on behalf of AutoWealth, including employees, agents, suppliers, or contractors.

4. Policy Requirements

4.1 AutoWealth Malaysia and its Associated Persons are prohibited from engaging in the following actions:

1. Bribery: Offering or accepting bribes in any form to gain a business advantage.
2. Facilitation Payments: Paying or receiving small unofficial payments to speed up a routine action.
3. Gifts and Entertainment: Offering or receiving gifts, entertainment, or hospitality that could be perceived as improper or intended to influence a business decision.

All business transactions must be carried out with integrity, transparency, and must be fully documented and authorised.

5. Facilitation Payments and Bribery

5.1 AutoWealth will not pay any facilitation payments under any circumstances. Employees shall not promise, offer, or agree to give or offer facilitation payments to public officials, nor are they permitted to pay such requests. Facilitation payments are considered a form of bribery and corruption.

5.2 If any employee, director, or Associated Person receives a request to make a payment for a facilitation payment on behalf of AutoWealth, they should exercise caution and:

1. Assess the purpose of the payment and determine whether the amount requested is reasonable for the goods or services provided.
2. Evaluate whether the requirement for the payment is clearly stated or documented in any source.
3. Take detailed notes of all conversations and correspondence related to the request.
4. Retain any papers or documents received in connection with the request.
5. Document any requests in writing to provide a record of the demand for payment.
6. Request a receipt that explicitly describes the purpose of the payment.

In the event that employees face a request from public officials or government officials for facilitation payments, the AutoWealth Malaysia’s Anti-Bribery Policy shall be communicated to the relevant party. The receipt of such requests must be immediately reported to the respective heads of department or unit heads.

5.3. All employees, directors, and Associated Persons must refrain from engaging in any activities that could result in bribery or suggest that AutoWealth Malaysia pays or accepts facilitation payments.

6. Gifts, Entertainment, and Hospitality

6.1 AutoWealth recognizes that exchanging gifts or offering hospitality is a customary practice in many cultures. However, all such exchanges must adhere to the following guidelines:

1. Gifts or hospitality must not exceed customary business practices and must not create an obligation on the recipient.
2. The giving or receiving of gifts and hospitality should be for legitimate business purposes only.
3. All gifts and hospitality must be reported and recorded. High-value items must receive approval from the senior management or compliance team.

7. Charitable Donations and Sponsorships

7.1 AutoWealth may support charitable causes and sponsorships, but these must never be used as a disguise for bribery. Any charitable donations or sponsorships must:

1. Be made for legitimate purposes.
2. Be approved and documented.
3. Not be made with the intent to gain any improper advantage

8. Political Contributions

8.1 AutoWealth does not make any contributions to political parties, candidates, or officials. Any personal political contributions by employees or directors must be clearly separate from AutoWealth and must never be made on behalf of the company.

9. Roles and Responsibilities

9.1 All Employees, Directors, and Associated Persons should carry out their following duties and obligations toward AutoWealth’s Anti-Bribery and Anti-Corruption:

1. All employees, directors, and Associated Persons must not participate in or facilitate any form of bribery or corruption, which may include abuse of power, breach of trust, collusion, embezzlement, extortion, fraud, or money laundering.
2. Each individual must be familiar with the provisions of this policy and understand their responsibilities regarding compliance
3. Associated Persons must establish and maintain adequate anti-bribery and anti-corruption controls within their operations.
4. All employees must accurately record all transactions and payments with sufficient detail and supporting documentation that can be cross-referenced. Financial records must comply with applicable laws and accounting principles.
5. Any suspicious transactions or indicators of bribery and corruption must be raised promptly to a supervisor or the Compliance Team. Additionally, all employees must report any violations or suspected violations in accordance with this policy.

9.2 Board of Directors of AutoWealth is responsible as following:

1. The Board of Directors is responsible for establishing an appropriate governance framework to ensure compliance with this policy and related procedures.
2. The Board may allocate necessary resources, including the internal audit function, to review and assess compliance with anti-bribery and anti-corruption matters.
3. The Board will monitor the effectiveness of the ABC policy and make necessary adjustments based on audit findings and compliance assessments.

9.3. The Compliance Team shall:

1. Oversee the implementation of compliance controls related to this policy and lead the design and provision of anti-bribery and anti-corruption communications and training.
2. Provide advice and guidance on the policy, including addressing any issues related to bribery and corruption.
3. Ensure adequate and periodic monitoring, measurement, analysis, and evaluation of the policy’s effectiveness are performed.
4. Conduct periodic risk assessments to identify bribery and corruption risks that could potentially affect AutoWealth Malaysia. The Compliance Team may engage all employees, directors, and Associated Persons to facilitate the risk assessment process, gather information, and evaluate risks as deemed appropriate.

9.4 Compliance with Record-Keeping and Reporting Standards

AutoWealth Malaysia shall maintain financial records in line with applicable laws and regulations, ensuring that there are appropriate internal controls to evidence any business reasons for payments, including payments to Associated Persons. No accounts shall be maintained “off-book” to facilitate or conceal improper payments, and any false or deceptive entries in books and records are strictly prohibited.

10. Conflict of Interest

10.1 Conflicts of interest arise when an individual’s personal interests have the potential to interfere with their objectivity in performing their duties or exercising judgement on behalf of AutoWealth. It is essential for all employees, directors, and Associated Persons to avoid situations where personal interests may conflict with their professional responsibilities.

10.2 A conflict of interest may arise in situations such as, but not limited to:

1. Taking a job with another company that could affect your duties at AutoWealth.
2. Recruiting or hiring a family member or friend to gain a business advantage.
3. Owning shares or having a financial stake in a competitor or client while being involved in decisions about them.
4. Participating in any activities that compete with,or could be perceived as competing with, AutoWealth’s interests.
5. Allowing personal or family interests affect business decisions.

All employees, directors, and Associated Persons are required to avoid all circumstances where personal or family interests may conflict with their professional duties, obligations, and responsibilities without exception.Promptly disclose any actual or potential conflicts of interest to their supervisor or the Compliance Team. Transparency is critical to maintaining integrity and trust. Adhere to the provisions related to conflicts of interest as outlined in AutoWealth’s Compliance Manual and Code of Ethics shall further apply to the staff and the Directors.

11.Recruitment Policy

11.1 AutoWealth Malaysia is an equal opportunity employer dedicated to recruiting qualified and competent individuals as employees, including both paid and unpaid interns, without discrimination based on background, including any associations with government officials or business partners. The recruitment process is governed by approved selection criteria to ensure the hiring of only the most suitable candidates, thereby mitigating any risks related to bribery and corruption.

11.2 Thorough background screening of prospective employees and interns will be conducted in accordance with AutoWealth’s hiring procedures. This includes checks to confirm that candidates have not been previously convicted of bribery-related offenses. Candidates applying for managerial positions or roles with decision-making responsibilities will undergo a more rigorous integrity assessment to ensure alignment with AutoWealth’s core ethical values. Upon recruitment, all employees and interns are required to acknowledge and agree to comply with the principles outlined in this Anti-Bribery and Anti-Corruption Policy.

12. Reporting Violations

12.1 Employees, directors, or Associated Persons of AutoWealth who are aware of any actions that violate or may violate this policy are required to report the activity immediately to his/her supervisor or the Compliance Team. This requirement holds true regardless of whether the actions have ceased. When making an anonymous report, the whistleblower must provide enough details to facilitate a proper investigation.

12.2 Individuals can report confidentially via email at _____@autowealth.com. Alternatively, reports can be delivered directly to the Compliance Officer in a sealed envelope labeled “Confidential.”

12.3 While AutoWealth encourages employees to come forward, anonymous reports are not preferred, as they can complicate investigations due to the lack of follow-up. Although AutoWealth is not required to investigate anonymous claims, it may still consider doing so based on:

1. The seriousness of the concern.
2. The credibility of the information.
3. The feasibility of verifying the concern from reliable sources

12.4. AutoWealth is dedicated to maintaining the confidentiality of whistleblowers, particularly their identities. However, there may be situations during an investigation where revealing the whistleblower’s identity is necessary. In such cases, the Compliance Officer will make an effort to inform the whistleblower that their identity may be disclosed and will seek their consent before proceeding. Any individual who becomes aware of a whistleblower’s identity is strictly forbidden from disclosing this information.

12.5. Employees or directors who report violations in good faith are protected against any form of retaliation, including unjust dismissal, victimisation, demotion, suspension, harassment, discrimination, or any other detrimental actions (“Detrimental Action”).Any reported violation, even if not verified by an investigation, will be eligible for protection under this policy.

12.6. However, a staff or a Director may not claim protection against Detrimental Action if:

1. The report is not made in good faith.
2. The individual has been involved in the reported violation
3. The report is made primarily to evade disciplinary action or termination.

12.7 Good faith will be deemed absent if:

1. The individual lacks personal knowledge or factual basis for the report.
2. The individual knew or should have known that the report or its contents were false.
3. The report is regarded as unimportant or meant to provoke irritation.
4. Any other circumstances suggest that the report was made with malicious intent, ulterior motives, or for personal gain.

12.8 AutoWealth Malaysia does not guarantee immunity from legal proceedings or prosecution related to reports made under this policy.

13. Training and Awareness

AutoWealth Malaysia is committed to ensuring that all employees and Associated Persons receive regular training on this policy and on how to identify and prevent bribery and corruption. New employees will receive this training during their onboarding, and all staff will participate in annual refresher courses.

14. Monitoring and Review

This policy will be reviewed and updated regularly to ensure it remains current and effective in combating bribery and corruption. The Compliance Team will carry out regular audits and monitoring to assess the policy’s implementation and the effectiveness of control measures.

15. Consequences of Non-Compliance

15.1 Violations of this policy may result in severe consequences for both individuals and the company. These may include:

1. Disciplinary actions, up to and including termination.
2. Legal penalties, such as fines and imprisonment, where applicable.
3. Damage to reputation and loss of business.

15.2 AutoWealth Malaysia will fully cooperate with regulatory and law enforcement authorities investigating any suspected bribery or corruption.