Anti-Bribery and Corruption Policy

Metro Healthcare Berhad and its subsidiaries are committed to ethical, transparent, and responsible business practices. This policy aligns with the Malaysian Anti-Corruption Commission Act 2009 and sets guidelines for preventing bribery and corruption.

Objectives
- To define the Group’s stance on bribery and corruption.
- To ensure compliance with anti-corruption laws.
- To take measures to prevent corrupt activities.
- To provide procedures and protection for handling corruption issues.
Scope
- Applicable to all Directors, employees, and Business Associates.
- Covers business dealings in all jurisdictions.
Anti-bribery and Corruption Principles
- Zero-tolerance for corruption.
- Commitment to ethical business practices.
- Full cooperation with enforcement agencies during investigations.
- Reporting mechanism for suspicions or breaches.
Sponsorships and Donations
- Donations and sponsorships are permissible with transparency.
- Donations to influence decisions or cover up bribery are strictly prohibited.
- Donations must be accurately recorded in accounting books.
Facilitation Payments and Kickbacks
- Strict prohibition on facilitation payments and kickbacks.
- Exceptions are allowed in emergencies with approval.
- Immediate reporting of requests for such payments.
Gifts, Hospitality, and Entertainment
- “No Gift Policy” with limited exceptions.
- Hospitality and entertainment arrangements are permitted if reasonable and transparent.
- Criteria for acceptable gifts and entertainment.
Conflict of Interest
- Prohibits the use of official positions for personal gain.
- Requires disclosure of conflicts of interest.
Business Associates
- Ethical practices from Business Associates are expected.
- Contractual agreements against bribery are required.
- Periodic risk assessments for potential partners.
Communication and Training
- Regular training on anti-corruption laws and policy compliance.
- Declaration by Employees confirming understanding and compliance.
Confidentiality and Protection
- Whistleblowing mechanism for reporting violations.
- Confidentiality and protection for whistleblowers.
Monitoring and Review
- Employees and Business Associates shall be responsible for adherence.
- Regular internal audits and risk assessments.
- Periodic reviews to ensure policy effectiveness.
Records-keeping
- Maintenance of accurate records for all payments.
- No “off-book” accounts.
- Records of declarations by Employees and Business Associates.
Compliance With the Law
- Commitment to compliance with applicable laws.
- Right to report criminal activities to authorities.
Periodic Review
- Policy shall be reviewed at least once every three years.
- More frequent reviews for legislative changes or business circumstances.
Board Approval
- Policy approved by the Board of Directors.
- Amendments shall be subjected to Board approval.