1. Introduction

Multi-Usage Holdings Berhad and its subsidiaries (collectively referred to as the "Group") are committed to conducting their business dealings with integrity and ethics. The Group practices a zero-tolerance approach against all forms of bribery and corruption, and upholds all applicable laws in relation to anti-bribery and corruption.

This policy is available at the Group's website at www.muh.com.my


2. Scope and Applicability

This Policy is applicable to all employees, including those who are full time, probationary, contract and temporary employees (collectively referred to as "Employees") as well as Directors of the Group. It is also expected that all third parties such as contractors, sub-contractors, consultants, advisers, agents, distributors, representatives and other persons or entities performing work or services for or on behalf of the Group ("Third Parties") comply with this Policy.

Should there be any conflicts between this policy and applicable laws, the law shall prevail.


3. Definition of Bribery and Corruption

"Corruption" or "Bribery" refers to the act of corruptly giving, agreeing to give, promising, offering, soliciting, receiving, or agreeing to receive any gratification. Gratification can take various forms, including monetary, non-monetary, services, favours, or any form of benefit or advantage. For the purpose of this Policy, the term "bribery" can be used interchangeably with "corruption" as specified in Paragraph 15.29 of the Main Market Listing Requirements issued by Bursa Malaysia Securities Berhad.

A gratification that is given or received with a corrupt intent, including to induce or reward the improper performance of a party, or to obtain or retain an undue advantage, is considered a bribe.

The MACC Act 2009 prohibits a person or a commercial organisation from giving and receiving bribes, including via agents or associates. [Refer to Section 16, Section 17, and Section 17A of the MACC Act 2009]


4. Gifts, Hospitality and Entertainment

This practice of giving and receiving reasonable and proportionate hospitality, gifts and entertainment is acceptable. However, Directors and Employees are prohibited from receiving or giving hospitality, gift and entertainment where these may have a significant influence or bearing on the person performing their duties impartially.

As a guiding principle, Directors and Employees may offer and receive gifts, hospitality and entertainment provided that such gift, hospitality and entertainment is appropriate, reasonable and acceptable in the normal course of business. When determining whether such gifts, hospitality or entertainment is permissible, Directors and Employees should take into account, considerations such as the intention and timing, transparency, frequency, compliance with the other party's policies and rules and the legality of such gift, hospitality and entertainment.

Certain types of gift, hospitality and entertainment are not permissible. As a guiding principle, the following gifts, hospitality and entertainment are strictly prohibited:

(a) Any gift, hospitality or entertainment that is illegal or in breach of any laws, regulations or rules;

(b) Any gift, hospitality or entertainment offered to a Government Official to facilitate or expedite a routine procedure;

(c) Gifts, hospitality or entertainment involving parties currently engaged in a tender or competitive bidding process;

(d) Gifts made in cash or cash equivalent i.e. anything that can be easily converted to cash;

(e) Any hospitality or entertainment that are sexually oriented;

(f) Any gift, hospitality or entertainment that is a "quid pro quo", i.e. something offered in return for something else such as business advantage; and

(g) Any gift, hospitality or entertainment that is paid for personally to avoid having to declare or seek approval for.

It is pertinent to bear in mind the broader context in which the gift, hospitality and/or entertainment is offered or received. Any gift, hospitality or entertainment that may appear or be perceived as influencing or compromising the judgment or objectiveness of the recipient shall not be offered or received.


5. Charitable Donations and Sponsorships

Donations (including charitable contributions) and sponsorships made by the Group and person associated are philanthropic in nature or for the purpose of promoting the Group and must never be made with the intention to, or perceived to be able to, influence any business-related decisions or outcome.

Suppliers, Service Providers, Business Associates, and any Third Parties acting on the Group's behalf shall not donate to or sponsor an event with the intention to obtain or retain a business-related decision or an advantage in the conduct of business on behalf or for the Group.

Donations (including charitable contributions) and sponsorships are ringfenced specifically for a clear environmental or social cause are permitted, subject to Managing Director's approval.

The Group shall not make any donation or sponsorship that comes with a direct or indirect suggestion, hint, inducement, understanding or implication that some expected or desirable outcome is required, or that is illegal or in breach of any applicable laws.

In principle, the Group does not make any financial or in-kind contribution to political parties, political party officials or candidates for political office, unless it is allowed under the relevant laws and regulations and the same must be made without expectation or promise of favourable treatment towards the Group.


6. Facilitation Payments

The Group, its Directors, Employees, Suppliers, Service Providers, and Business Associates are prohibited from, directly or through a third party, giving, receiving, or promising of facilitation payments of all kinds. Facilitation payments include unofficial and improper payments or benefits provided to secure or expedite a business-related outcome or decision for the Group. Facilitation payments may be seen as a bribe and they could be small in value and solicited by both the public and private sectors.


7. Business Rewards, Rebates, Commissions, or Other Incentives

Doing business or establishing new business opportunities may involve the use of various promotional and marketing tools such as business rewards, rebates, discounts, or other incentives. That said, certain business rewards or incentives may be of questionable nature or worse, they may constitute a bribe formulated with the intention to obtain or retain an undue business advantage.

I) The Group does not provide business rewards, rebates, commissions, or other incentives which are questionable in nature or are contradictory with anti-corruption laws and regulations.

ii) Business-related incentives of the Group must fulfil the following conditions:

• is formally documented as part of the provider's (of the business incentive) incentive program or contract (e.g. rewards program or credit policy); and
• is applicable to all or its applicability is based on business-based parameters (e.g. applicable to all customers or applicable to customers exceeding certain order amount).

Suppliers, Service Providers, Business Associates, and any Third Parties acting on the Group's behalf shall uphold the above policy in the conduct of business on behalf or for the Group.


8. Sanction for Non-Compliance

Directors, and Employees of the Group are expected to refuse to give or receive a bribe when solicited or offered one. The Group is committed to ensuring that no one will suffers demotion, penalty or other adverse consequences in retaliation for refusing to pay or receive bribes or participate in other illicit behaviour.

Anyone who encounters actual or suspected violation of this Policy is required to report their concerns to Managing Director or Audit Committee Chairman. Retaliation in any form against the person who has reported a violation or possible violation of the Policy is strictly prohibited.

The Group regards bribery and acts of corruption as serious matters and will apply penalties in the event of non-compliance to this policy. For personnel, non-compliance may lead to disciplinary action, up to and including termination of employment.

For external parties, non-compliance may lead to penalties including termination of contract. Further legal action may also be taken in the event that the Group's interests have been harmed by the results on non-compliance by individuals and organisations.

The Group reserves the right to report any action or activity suspected to be in criminal nature to authorities.


9. Review of this Policy

This Policy is approved by the Board of Directors of Multi-Usage Holdings Berhad on 19 October 2020.

This Policy shall be reviewed by the Company periodically to improve the existing anti-bribery and corruption controls within the Group.