{"id":3897,"date":"2020-07-13T13:19:28","date_gmt":"2020-07-13T05:19:28","guid":{"rendered":"https:\/\/www.tvesc.com\/?page_id=3897"},"modified":"2021-01-07T11:11:39","modified_gmt":"2021-01-07T03:11:39","slug":"anti-bribery-corruption-policy","status":"publish","type":"page","link":"https:\/\/www.tvesc.com\/en\/anti-bribery-corruption-policy\/","title":{"rendered":"Anti Bribery & Corruption Policy"},"content":{"rendered":"\t\t
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INTRODUCTION<\/h3>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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The Anti-Bribery and Corruption Policy (\u201cPolicy\u201d) of TOPVISION EYE SPECIALIST BERHAD (\u201cTOPVISION\u201d or \u201cCompany\u201d) and its subsidiaries (\u201cGroup\u201d) is drafted in accordance to sub section (5) of Section 17A under the Malaysian Anti-Corruption Commission Act 2009 and the Malaysian Anti-Corruption Commission (Amendment) Act 2018, the Anti-Bribery and Corruption Policy based on the Guidelines on Adequate Procedures issued by the National Centre For Governance, Integrity and Anti-Corruption (GIACC).<\/p>

TOPVISION is committed in ensuring that the Group meets its legal obligations and prevents, detects, minimises and eliminates all form of corrupt practices. The Policy encompasses an ethical framework that serves as a guide to the actions and behavior of all Directors, employees of the Group and business associates which include but are not limited to current or prospective customers, joint venture or business partners, contractors, vendors, suppliers, distributors, outsourcing providers, consultants, agents, investors, advisers, associates, representatives or any other business partners (\u201cBusiness Associate\u201d) in the ordinary course of its business activities. It is reflective of the ever increasing need for effective corporate governance compliance measures in the conduct of the Group\u2019s businesses. The Policy focuses on discipline, good conduct, professionalism, loyalty and integrity, and cohesiveness, which are seen to be critical success indicators of the Group. The Group will take reasonable and appropriate measures to ensure that its businesses do not participate in corrupt activities for its advantage or benefit.<\/p>

This Policy is supplemental to and shall be read together with TOPVISION\u2019s internal policies and procedures, Whistleblowing Policy and Code of Ethics and Conduct.<\/p><\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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OBJECTIVE<\/h3>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Serves to ensure all Directors, employees of the Group and Business Associate are guided on standards of behaviour to be in compliance with all applicable laws, rules and regulations in discharging their duties. The policy is non- exhaustive and is subject to review to further include additional obligations that the Directors, employees of the Group and Business Associate are expected to adhere to in the performance of their duties.<\/p><\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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SCOPE<\/h3>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Applicable to all Directors (Executive and Non-Executive) of the Group, employees (including full-time, probationary, contract and temporary staff) of the Group and Business Associate. Each employee of the Group has a duty to read and understand the policy. Violation of any of the policy\u2019s provisions may result in disciplinary action, including termination of employment.<\/p><\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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DEFINITION OF BRIBERY, CORRUPTION AND GRATIFICATION<\/h3>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Bribery<\/strong>
For the purpose of this Policy, bribery includes, but is not limited to, the promising or granting or the requesting or receiving of benefits in money or money\u2019s worth to a person with the aim of influencing that person in order to obtain business or reward improperly or to gain any improper commercial, contractual, regulatory or personal advantage. It is the offer, promise, giving, soliciting, demanding or acceptance of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. The most obvious form of inducement is the giving \/ offer of money, gifts, loans, fees, rewards, goods or an advantage, but it can include the promise of favours in the future.<\/p>

Corruption<\/strong>
Corruption is the abuse of entrusted power for personal gain. Conflict of interest may arise in situations where personal interest either interfere, has the potential to interference, or is perceived to interfere with :-<\/p>

  • objectivity in performing professional obligations and duties.<\/li>
  • exercising of judgement in the discharge of duties and responsibilities as well as in decision making.<\/li><\/ul>

    The individual\u2019s official position, company\u2019s working hours, resources and assets or information accessible to him or her may be misused for personal interest or to the company\u2019s disadvantage.<\/p>

    Gratification <\/strong>
    Definition under section 3 of Malaysian Anti-Corruption Commission Act 2009<\/em><\/p>

    • money, donation, gift, loan, fee, reward, valuable security, property or interest in property being property of any description whether movable or immovable, financial benefit, or any other similar advantage;<\/li>
    • any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;<\/li>
    • any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;<\/li>
    • any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;<\/li>
    • any forbearance to demand any money or money\u2019s worth or valuable thing;<\/li>
    • any other service or favour of any description, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted, and including the exercise or the forbearance from the exercise of any right or any official power or duty; and<\/li>
    • any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs (a) to (f).<\/li><\/ul>

      Application <\/strong>
      This Policy is not set out to prohibit common practices which are proportionate, properly recorded, and lawful in the jurisdiction they are carried out. Practices that are aimed at establishing\/strengthening relationships with suppliers and customers while promoting the Group\u2019s products and\/or services, must be carried out in moderation, be transparent without expecting the recipient to reciprocate either by performing, or failing to perform, any other task in return.<\/p><\/div>\n\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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      COMMON FORMS OF BRIBERY & CORRUPTION<\/h3>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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      Gifts<\/strong>
      Policy on Accepting Gifts by Third Parties or Giving Gifts to Third Parties<\/strong><\/p>

      The Group\u2019s policy on accepting gifts by third parties or giving gifts to third parties does not prohibit normal and transparent gifts that are deemed appropriate in nature, moderate in value, occasional and bona fide corporate hospitality, in the course of ordinary business, unless :-<\/p>