1. Purpose
Exact Security Services is committed to operating with integrity, transparency, and accountability in all aspects of our business.
This Anti-Bribery and Corruption Policy (“the Policy”) establishes clear standards to prevent, detect, and respond to any form of bribery or corrupt practices within our organization.
2. Scope
This Policy applies to:
- All employees, security guards, management, and directors of Exact Security Services.
- All contractors, suppliers, consultants, and agents acting on behalf of the company.
- All business operations conducted in Malaysia and any other territories where we operate.
3. Policy Statement
Exact Security Services has zero tolerance for bribery and corruption.
We strictly prohibit any person representing the company from offering, giving, soliciting, or receiving bribes in any form, whether directly or indirectly, for the purpose of obtaining or retaining business, influence, or any unfair advantage.
4. Definition of Bribery and Corruption
- Bribery refers to giving, offering, receiving, or soliciting anything of value to influence a business decision or action.
- Corruption refers to dishonest or fraudulent conduct by a person entrusted with power, typically involving bribery.
- “Anything of value” includes money, gifts, entertainment, services, favors, employment offers, or other benefits.
5. Prohibited Acts
All employees and representatives are strictly prohibited from:
- Offering or accepting bribes, kickbacks, or facilitation payments.
- Giving gifts or entertainment intended to influence decisions or gain favor.
- Making political donations on behalf of the company.
- Manipulating or falsifying financial or operational records.
- Engaging intermediaries or agents to perform corrupt acts on behalf of the company.
6. Gifts, Entertainment & Hospitality
- Modest and reasonable gifts or hospitality may be accepted only if they are lawful, customary, and not intended to influence a business decision.
- All gifts or hospitality above RM300 in value must be declared to management.
- Any suspicion of intent to gain unfair advantage must be reported immediately.
7. Responsibilities
7.1 Employees
- Must read, understand, and comply with this Policy.
- Must report any actual or suspected act of bribery or corruption.
7.2 Management
- Must lead by example and promote a culture of honesty and integrity.
- Must ensure all employees receive proper training on anti-corruption practices.
7.3 Third Parties
- All contractors, vendors, and business partners must adhere to this Policy and sign relevant declarations when engaging with the company.
8. Reporting & Whistleblowing
- Employees are encouraged to report any concerns or suspected violations through the Grievance/Whistleblowing Channel.
- Reports may be made confidentially or anonymously.
- No employee will face retaliation or disciplinary action for reporting in good faith.
Whistleblowing Contact:
Email: [Insert Whistleblowing Email Address]
Phone: [Insert Contact Number]
Attention: Compliance/HR Department
9. Record-Keeping
- All transactions, payments, and expenses must be accurately recorded and supported by documentation.
- No “off-the-record” accounts or false invoices are permitted.
10. Training & Communication
- Regular anti-bribery and corruption training will be provided to all staff, especially those involved in operations, procurement, and client engagement.
- This Policy shall be accessible on the company’s website and employee handbook.
11. Consequences of Violation
Any employee found to have violated this Policy will face disciplinary action, which may include termination of employment and reporting to the Malaysian Anti-Corruption Commission (MACC).
Business partners or contractors found in breach may have their contracts terminated immediately.
12. Continuous Improvement
Exact Security Services commits to reviewing and updating this Policy periodically to ensure effectiveness, compliance with law, and alignment with best industry practices.
13. Acknowledgment
All employees and partners must sign an acknowledgment form confirming that they have read, understood, and agreed to comply with this Policy.