Anti-Bribery & Corruption Policy

1.
Purpose

TF Value-Mart strive to uphold the highest standard of professional integrity and ethical conduct required of every TF Value-Mart’s partner, officer, employee and third parties who perform services for and on behalf of TF Value-Mart and/or conduct business transaction with TF Value-Mart.

TF Value-Mart and all its employees are committed to comply with the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act 2009”), which shall include any modification or re-enactment of that legislation or any legislative provision substituted for, and all regulations and statutory instruments issued under such legislation or provision.

This policy provides an overview of TF Value-Mart’s Anti-Bribery & Anti-Corruption Policy and explains the basic and minimum requirements and obligations that TF Value-Mart’s Employees (hereinafter defined) and Associated Persons (hereinafter defined) shall aware of to disclose any corruptions, briberies, conflicts of interest or similar unethical act and/or practices that they may have and further to avoid any such corruptions, briberies, conflicts of interest or similar unethical act and/or practices throughout their business transaction with TF Value-Mart.

2.
Scope

This policy is applicable to all TF Value-Mart’s Employees. Joint Venture companies in which TF Value-Mart is a non-controlling shareholder or partner and associated companies are encouraged to adopt this policy as the bare minimum or similar principles and standards as part of their anti-corruption framework.

The term “TF Value-Mart”, “the Company”, “we”, “us” or “our” when used in this policy shall refer to TF Value-Mart Sdn. Bhd. and its subsidiaries, if any, and the term “you” or “your” shall refer to each of our Employee or Associated Person individually and in the case of Associated Persons, including any entity which is controlled by our Associated Persons, unless the context indicates otherwise.

3.
Definitions
3.1
Definitions

All partners, employees, directors (executive and non-executive) and associates of TF Value-Mart, including temporary, contract staff or interns.

3.2
Associated Persons

Such other parties engaged by TF Value-Mart or performing work or services for and on behalf of TF Value-Mart, including contractors, sub-contractors, consultants, agents, representatives and service providers of all kind.

3.3
Top Level Management
  1. A person who is director, controller, officer or partner of the Company; or
  2. A person who is concerned in the management of the Company’s affair.
3.4
Corruption
  1. Giving and/or receiving of any gratification or reward in the form of cash or in-kind of high value for performing a task in relation to his/her job function or activity.
  2. Soliciting and/or accepting and/or agreeing to receive (directly or through an agent) gratification for oneself or any other person, as an inducement or reward for doing or forbearing to do something.
  3. Offering and/or giving and/or promising to give (directly or through an agent or other person associated with the Company) gratification for the benefit of that person or of another person as an inducement or reward for doing or forbearing to do something, or with the intent to obtain or retain a business or advantage for the Company.
  4. Intending to deceive principal.
  5. Procuring withdrawal of tender.
  6. Using office or position for gratification.
  7. Offering and/or giving gratification by commercial organization (corporate liability).
  8. Deemed parallel personal liability for senior personnel (personal liability).
3.5
Improper Advantage

Any benefit provided in return for the misuse of the receiver’s position, task or assignment will generally be considered an improper advantage.

An improper advantage will usually be a benefit in the form of cash or objects with economic value but may also include benefits without economic value. Personal benefits provided in relation to the recipient’s position, task or assignment, such as services carried out for free or with a discount, invitations to otherwise private organizations or clubs may easily be regarded as improper.

The most evident examples of corruptive improper advantage are:

  • paying to obtain a contract
  • receiving payment (cash, gifts or services) personally
3.6
Bribery or “trading in influence”

Any offering, promising, giving, requesting, agreeing to receive, accepting a gratification or other advantages with the intention of inducing or rewarding someone to perform their job function or activity improperly. Form of bribery includes kickbacks, inflated commissions, expensive gifts, political donations, excessive or inappropriate entertainment.

3.7
Facilitation Payments

Facilitation payments are form of payments made personally to an individual in control of a process or decision to secure or expedite the performance of a routine or administrative duty or function (e.g. influencing the timing of process or issuing of permits).

3.8
Public and Private Sector Payments

TF Value-Mart prohibit corrupt payments to any person, both in the public and private sector. Any kind of corrupt activity, whether this activity is related to a position, assignment or duty within the public or private sector, will falls within this TF Value-Mart’s Anti-Bribery & Anti-Corruption Policy.

3.9
Liability for Corrupt Acts of Agents and Other Representatives

Corruption may also include payments made by agents, subsidiaries, affiliates or others acting on behalf of the parent company or as part of the parent company.

3.10
Gratification
  • 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;
  • Any office, dignity, employment, contract of employment or services, and agreement to give employment or render services in any capacity;
  • Any payment, release, discharge or liquidation of any loan, obligation or other liability;
  • Any valuable consideration of any kind, any discount, commission, rebate, bonus, deduction or percentage;
  • Any forbearance to demand any money or money’s worth or valuable thing;
  • 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; and
  • Any offer, undertaking or promise, whether conditional or unconditional, of any gratification within the meaning of any of the preceding paragraphs as stated in this Clause.
4.
Key requirements and main offences under MACC Act
4.1
Soliciting or receiving gratification
  • Any person who solicits or receives or agree to receive (for himself or any other person) or gives, promises or offers to any person any gratification as an inducement to or a reward for any person doing or forbearing to do anything.
  • Any person accepts or obtains or agrees to the same, any gratification as an inducement or reward for doing or forbearing to do, any act in relation to his principal’s affair or business, or for showing or forbearing to show favour or disfavour to any person in relation to his principal’s affairs or business commits an offence.
4.2
Offering or giving gratification
  • any person who gives or agrees to give or offers any gratification to any agent as inducement or reward for doing or forbearing to do, or for having done or forborne to do the same in relation to his principal’s affairs or business, or for showing or forbearing to show favour or disfavour to any person in relation to his principal’s affairs or business.
4.3
Intending to deceive
  • any person who gives to an agent, or being an agent, uses with intent to deceive his principal, any receipt, account or other document in respect of which the principal is interested, and which he has reason to believe contains any statement which is false or erroneous or defective in any material particular, and is intended to mislead the principal.
4.4
Using office or position for gratification (abuse of position)
4.5
Failing to report when offered bribery
  • any person to whom any gratification is given, promised or offered in contravention of MACC Act 2009 shall report the same.
4.6
Section 17A of MACC Act 2009
  • Upon Section 17A of MACC Act 2009 coming into effect, a commercial organization commits an offence if a person associated to the commercial organization corruptly gives, agrees to give, promises or offers to any person any gratification whether for the benefit of that person or another person with intent to obtain or retain business for the commercial organization and/or to obtain or retain an advantage in the conduct of business for commercial organization.
  • Where an offence is committed by a commercial organization, the Top-Level Management, at the time of the commission of the offence, is deemed to have committed the offence unless the person proves that the offence was committed without his consent or knowledge and that he exercised the adequate due diligence to prevent the commission of the offence as he ought to have exercised, having regard to the nature of his function in that capacity and to the circumstances.
  • Under the MACC Act 2009 (revised 2018), bribery and corruption are criminal offences and the legal consequences include fine of unlimited amount and/or imprisonment of up to twenty (20) years. A commercial organization commits an offence if an associated person corruptly gives any gratification with intent to obtain or retain business or an advantage in the conduct of business, for the commercial organization.
  • If an offence is committed by a commercial organization, the MACC Act also deems its directors, controllers, officers, partners or persons concerned in its management of affairs to have committed the same offence. It is therefore important that you understand how bribery and corruption may be committed and the legal consequences arising from such act as well as to take steps to prevent bribery and corruption from happening.
5.
Guidelines and Policy

TF Value-Mart is committed to work actively against corruption and bribery by running its business operation on a foundation of integrity and transparency.

TF Value-Mart adopts a zero-tolerance policy towards any forms of corruption and bribery in the business. The Company and employees are required to observe the anti-bribery and anti-corruption legislations and regulations in the country where the Company have business activities in and do not engage in any corrupt or improper practices.

5.1
Anti-Bribery & Anti-Corruption
  1. All Employees and Associated Persons are not permitted to pay, offer, accept or receive a bribe in any form. All Employees and Associated Persons are strictly NOT allowed to:-
    1. Offer, pay or give anything of value to any parties in order to obtain business or with the intention to obtain or retain business or advantages for the organization of TF Value-Mart.
    2. Act illegally including bribes, blackmail, induce, provide secret commissions, other rewards and/or any other similar improper action.
    3. Attempt to induce any parties to do something illegal, unethical and permit any parties to violate the rules.
    4. Give some advantage inconsistent with law and wrongful or unlawful use of official position to procure some benefit or personal gain.
    5. Corruptly give, promise or offer to any person gratification with the intent to secure business or an advantage to TF Value-Mart.
    6. Offer, give, receive or solicit, directly or indirectly, anything of value to influence improperly the actions of another party.
5.2
Conflicts of Interest
  1. Conflicts of interest occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another. A conflict of interest may be actual, potential or perceived and may be financial or non-financial.
  2. It is the responsibility of TF Value-Mart and all the Employees and Associated Persons to avoid any ethical, legal, financial or other conflicts of interest and to ensure any such conflicts (where they do arise) do not conflict with the obligations to TF Value-Mart.
  3. TF Value-Mart requires all the Employees and Associated Persons to:-
    1. Avoid any situation or activity that compromises, or any compromise, their judgment or ability to act in the best interest of TF Value-Mart.
    2. Avoid being in a position where their personal interests are in conflict (or could be in conflict) with interests or business of TF Value-Mart.
    3. Avoid engaging in activities that will bring direct or indirect profit, commercial or business advantages to TF Value-Mart’s competitor.
    4. Avoid acting in ways that may compromise TF Value-Mart’s legality.
    5. Identify and disclose any conflicts of interest.
    6. Carefully manage any conflicts of interest.
  4. All Employees must not use their position, official working hours, TF Value-Mart’s resources and assets or information available to them for person gain or to TF Value-Mart’s disadvantage.
  5. In the event where conflict of interest arises, Employees are required to immediately declare the matter to their immediate supervisor.
5.3
Gifts, Benefits, Hospitality and Travel
  1. Offering or receiving any gifts, benefits, hospitality and sponsored travel that may be perceived to unfairly influence a business relationship must be strictly avoided at all times. They should only be provided and/or received where they are appropriate, consistent with reasonable business practice, and would not be perceived to have any improper influence on the recipient.
  2. All Employees must not use their authority or office for personal gain, including must not request, accept, offer or provide gifts, benefits, hospitality and/or any sponsored travel designed to induce, support or reward improper conduct in connection with any business or anticipated future business involving TF Value-Mart.
  3. Each Employee should use good judgment in offering or receiving any gifts, benefit, hospitality and/or sponsored travel and shall has a personal responsibility and obligation to maintain an audit trail for all gifts, benefits, hospitality and/or sponsored travel offered and/or accepted and to make the necessary reporting under this Policy.
  4. Corporate Gift” normally bears the company’s name and logo and are of nominal/ appropriate value such as diaries, table calendars, pens, notepads and plaques. “Festive or ceremonial gifts” are traditional treats or gifts customary to the occasion such as red packets (without cash or cash equivalent), oranges and dates.
  5. Corporate gifts, festive or ceremonial gifts may be given to our Associated Persons or other parties only if ALL of the following conditions are fulfilled:-
    • Made for the right reason – it should be clearly given as an act of appreciation or common courtesy associated with festive seasons or other ceremonial occasions;
    • No obligation – it must not be used to cause or induce the receiver to improperly or illegally influence any business action or inaction or cause others to perceive an improper influence;
    • No expectation – there must not be any expectation of any favour or improper advantages from the receiver;
    • Made openly – if made secretly and undocumented then the purpose will be open to question;
    • Reasonable value – the type of gift and its value must commensurate with the occasion and in accordance with general business practice;
    • Legal – it complies with applicable laws; and
    • Documented – the expense must be approved in accordance with and complies with TF Value-Mart’s standard operating procedures.
  6. TF Value-Mart recognizes that exchange of gifts is a very delicate matter where, in certain cultures or situations, gift giving is customary, a tradition or central part of the business etiquette. Employees are expected to decline (or avoid accepting) gifts with the exceptions being:-
    • Corporate gifts of nominal / appropriate value;
    • Festive or ceremonial gifts of appropriate value during festive seasons or other ceremonial occasions;
    • When refusing the gift is likely to offend and harm TF Value-Mart’s business relationship with the giver; or
    • Gifts given during invitation to speak at conferences or work-related conferences.
  7. If Employee is in doubt about the acceptability, the gift must be refused.
  8. All Employees are only allowed to accept benefit, hospitality and/or sponsored travel from a third party only if ALL of the following conditions are fulfilled:-
    • General relationship building – It is aimed at nothing more than general relationship building;
    • No influence – It is not be perceived as an attempt to gain influence in respect of any particular matter;
    • Legal – It is legitimate and lawful in the country to offer such gift, benefit, hospitality and/or sponsored travel;
    • No undue pressure – It is offered voluntarily without undue pressure;
    • No Impropriety or embarrassment – Acceptance will neither influence the Employee’s performance of his/her official duties nor will it creates an appearance of impropriety or embarrassment to TF Value-Mart; and
    • Permitted – It is permitted under Schedule 1 hereto and the applicable local laws and regulations.
  9. All Employees are only allowed to offer a gift, benefit, hospitality and/or sponsored travel to a third party only if ALL of the following conditions are fulfilled:-
    • General relationship building – It is aimed at nothing more than general relationship building;
    • No influence – It could not be perceived as an attempt to gain influence in respect of any particular matter;
    • Legal – It is legitimate and lawful in the country to offer such gift, benefit, hospitality and/or sponsored travel;
    • No Impropriety or embarrassment – It is not offered to gain an unfair advantage and will not create an appearance of impropriety or embarrassment to TF Value-Mart; and
    • Permitted – The offer is permitted under Schedule 1 hereto and the applicable local laws and regulations.
  10. All gift and benefit offered and/or accepted must be declared by the employee by submitting the Gift & Benefit Declaration Form to the SLT for prior approval. A sample of the gift and benefit declaration form is attached as Schedule 2 hereto. Line managers are responsible to maintain records of the applications and the decisions and revert to the employee if they are concerned that there has been any breach of this Policy.
5.4
Government Officials

Employees are strictly prohibited from providing gifts, hospitality and entertainment to government officials and/or their family in contravention of applicable laws, regulations, policies and guidelines. Caution is advised before dealing with persons who are known or suspected to be family members of government officials or of companies that are known or suspected to be connected with or controlled by government officials and/or family members of government officials to avoid the possibility of these persons being the conduit for illicit or prohibited gifting, payments or hospitality to government officials under this policy or applicable laws.

A government official includes:

  • An officer or employee of a government or a department, agency, instrumentality of such government or any person acting in an official capacity for or on behalf of such government;
  • An officer or employee of a public international organization or any person acting in an official capacity for or on behalf of such public international organization (for example, the United Nations, the World Bank, etc.);
  • An employee or a company or other entity in which a governmental body has an ownership interest and/or over which such government body may directly or indirectly exercise a dominant influence; and
  • A political party or a member of a political party or a candidate for political office.

If any information is required by any government, government agencies, regulatory bodies, statutory bodies (whether local or foreign), our Employees must always consult their immediate supervisor before responding to such request and ensure that all information provided is in good faith, truthful and accurate.

Any improper or secret payments or transfer of items of any value (including facilitation payments) to government officials is strictly prohibited. If Employees have any doubts on whether such payments constitute an improper, secret and/or facilitation payments, please refer to Integrity Team.

Any improper or secret payments or transfer of items of value through intermediaries, or a third party, with the knowledge that all or part of the payment will contribute directly or indirectly as an improper, secret or facilitation payments to a government official is also strictly prohibited.

5.5
Political Contributions and/or Donation

It is TF Value-Mart’s policy that the company does NOT make or offer any kind of political contribution and/or donation to any political party, including their officials or any candidates for any political office.

5.6
Charitable Contribution, Donation and/or Sponsorships

Employees may only make or receive a charitable contribution, donation and/or sponsorship provided that it has been subject to due diligence and management approvals and is appropriate in all the circumstances. Always perform a background check on the charitable organization, its founders, its trustees and its managers.

Charitable contribution, donation and/or sponsorship of any form must be made to or received from a bona fide charitable organization or recipient and must not be made with the intention of obtaining or retaining business for TF Value-Mart or obtaining or retaining an advantage in the conduct of business for TF Value-Mart.

Employees must ensure that all contribution, donation and/or sponsorship are not made or received as subterfuge for bribery or used to circumvent or avoid any of TF Value-Mart’s policy, procedure, guideline, handbook, code and requirements. Employees must also ensure that contribution, donation and/or sponsorship to foreign based charitable organizations or recipients will not be disguised as illegal payment to any government officials and must be vigilant to ensure that the charitable organizations or recipients are not conduit to fund any illegal activity and/or against any money laundering, anti-terrorism and other applicable laws.

Contribution, donation and/or sponsorship to charitable organization shall only be made in non-monetary form and should not be solicited by any person who has any business connection or relationship with TF Value-Mart or made to any government official which may be perceived as a bribe or a gratification or through any charitable organization which may act as conduit for any improper payments to that person or government official.

If it is necessary for monetary contribution, donation and/or sponsorship, Employees must conduct the necessary due diligence on the use and purpose of such monetary contribution, donation and/or sponsorship. Top-Level Management may, approve to give monetary contribution, donation and/or sponsorship after completion of the due diligence and satisfied that the monetary contribution, donation and/or sponsorship is intended to use for bona fide purpose only.

5.7
Facilitation Payments

In Malaysia, facilitation payment is illegal and is seen as a form of corruption. Any form of facilitation payments is strictly prohibited in TF Value-Mart. All Employees of TF Value-Mart must not directly or indirectly offer, promise or give any form of facilitation payment to any public officials for any purposes.

In the event any employee of TF Value-Mart is forced to make facilitation payments in order to protect his/her life, limb or liberty, such employee must immediately report the incident to the company’s designated person for the necessary action to be taken.

5.8
Entertainment

It is a common practice within the business environment to provide entertainment to foster business relationship. TF Value-Mart recognizes the need to provide reasonable and proportionate entertainment under appropriate circumstances. Employees may offer appropriate and proportionate entertainment that is legal and reasonable within the scope of their work as part of business networking as well as a measure of goodwill towards the recipients.

Whilst the act of hospitality through entertainment is a central part of business etiquette, it may create a negative perception if observed or known by others despite selfless motives behind entertainment provided. Employees must always bear in mind that perception is more important than facts and therefore Employees are expected to always exercise proper care and good judgment when providing entertainment to external parties, especially when it involves public officials.

Employees must not directly or indirectly provide or offer to provide entertainment with a view to cause undue influence or in exchange for favours or advantages. Such acts are considered corruption and are strictly prohibit by the Company.

TF Value-Mart recognizes that occasional acceptance of appropriate and proportionate entertainment provided by Associated Persons and/or business partners and/or other third parties in the normal course of business is legitimate way to network and to build business relationship. However, it is important for the Employees to exercise proper care and good judgement before accepting entertainment offered or provided by Associated Persons and/or business partners and/or other third parties. This is to safeguard TF Value-Mart’s reputation and avoid allegations of impropriety or undue influence or worse, corruption.

Employees must at all times conduct themselves with integrity in relation to accepting entertainment from any party. Employees or any of their family members must not accept entertainment in exchange for an exercise or non-exercise of their job function or activity.

5.9
Accurate Accounting and Internal Controls

The Company is legally obliged to make and keep books, records and accounts that accurately and fairly reflect the transactions and disposition of the Company’s assets.

The use of false documents and invoices and the making of inadequate, ambiguous or deceptive bookkeeping entries and any other accounting procedure, technique or device that are intended or that have the effect of hiding or disguising illegal payments are strictly prohibited.

In line with good corporate governance practices, the Company has maintained a system of internal financial and accounting controls for the purpose of providing reasonable assurances that:

  • transactions are executed according to approved authority limits;
  • transactions are recorded as necessary to permit preparation of financial statements that conform with applicable or generally accepted accounting standards and to maintain accountability of assets; and
  • access to assets is permitted according to authorization.
5.10
Procurement Process

Corruption is more widespread in certain countries and operating in these countries can expose the Company to higher risks requiring greater precaution to guard against these risks.

Employees must at all times comply with the Company’s policy and procedures on procurement to enable the Company to demonstrate that procurement decisions are taken based on merit and not from exertions of undue influence by any person or government official or not by exerting undue influence on any person or government official.

Procurement policy and procedures will include rules on the timing of and process for securing bid information and documents and Associated Persons, business partners and/or such other third-parties involved in such bid must conform to such rules and not among others, seek non-public inside information in violation of such rules.

During tender processes, strict rules usually exist relating to conflicts of interest and interactions and communication with persons involved in the tender processes. Associated Persons, business partners and/or such other third-parties must not engage in any gift or hospitality giving or entertainment with such persons during the tender process.

Associated Persons, business partners and/or such other third-parties must be made fully aware and informed of the rules of such tender or general procurement guidelines.

5.11
TF Value-Mart’s Business Partners

All business decisions of the Company must be made based on merit. No Associated Person is authorized to corruptly give, agree to give, promise or offer to any person any gratification whether for the benefit of that person or another with the intent to obtain from or retain business for the Company or to obtain or retain an advantage in the conduct of business for the Company.

The Company undertakes due diligence or verification checks on its business partners (including agents, consultants, vendors, distributors, etc.) to assess the credit and corruption risk before commencing business with them. Employees must not commence or continue business dealings with such Associated Person if the results of the checks are unsatisfactory.

The requirement of due care will vary depending on the circumstances, but will always include the following steps:

  1. conducting integrity due diligence screening of potential business partner before engagement, meaning that it should be a real company with real business purposes, under which the relevant services fall under;
  2. formalizing the engagement by a written contract, including a clear description of the performance of work and provisions, including the possibility to leave a contractual obligation in case of corruption or bribery;
  3. ensuring that the payment for the services rendered is reasonable in relation to the services to be performed;
  4. third parties should not be referred by government officials;
  5. payments in cash are generally not permissible, and if unavoidable such payments must be supported by proper documentation;
  6. third parties may not be paid offshore or to another person’s account or payment in cash unless there are genuine and/or legitimate business reasons for such payment manner and it is supported by proper documentation and approved by the Top-Level Management. Tax avoidance or evasion can never be a proper justification for such payment manner.
  7. all third-party contracts must contain clauses that address anti-corruption.

Associated Person must submit a Third-Party Integrity Declaration Form or confirmation in similar terms prior to on-boarding as TF Value-Mart’s service provider.

Employees must monitor the Associated Persons’ performance from time to time to be in compliance with this policy and where breach or suspected breach arises, immediate action must be taken. Failure to comply with this policy by Associated Persons may lead to immediate termination of contract/engagement and claim for damages.

Unless otherwise stated, all Associated Persons are independent contractors. There are not agent or representative of TF Value-Mart and they are not entitled or must not hold themselves out to have the authority to bind TF Value-Mart for any purpose whatsoever and howsoever.

5.12
Consequences of Non-Compliance

The potential consequences of non-compliance with applicable anti-bribery and anti-corruption laws are substantial:

  • Corruption distorts free competition and undermines the rule of law.
  • Exposed corruption results in negative publicity, which can do serious damage to a company’s reputation and business relationships.
  • The decision by authorities to initiate investigation of a suspected anti-bribery and/or anti-corruption infringement may cause serious harm to the involved party’s reputation and business interests and trigger substantial costs.
  • Individuals involved in corrupt activities may be subject to criminal sanctions, including fines, imprisonment and even corporal punishment. Often, the individuals’ superior will also be subject to criminal sanctions if he/she knew or should have known that the corruptive act was conducted.
  • Section 17A of MACC Act 2009 must be observed by all Employees. The Company may on conviction be liable to a fine of 10 times the value of the gratification or RM1,000,000.00, whichever is the higher or imprisonment for not more than 20 years, or both.
  • Companies may be prohibited from doing business in certain countries or industries, with certain governments or from participating in public tenders.
  • Companies may be liable for damages claims by third parties disadvantaged by the corrupt activity, such as competitors who may have lost business.
  • Risk of criminal prosecution, dismissal or other disciplinary action for the individual.
6.
Whistleblowing & Reporting Channel

To encourage openness and transparency and in order to facilitate the reporting of potential or suspected violation of TF Value-Mart’s Policy or applicable laws, regulations or professional standards, including those relating to anti-bribery and anti-corruption. TF Value-Mart has established an accessible and trusted whistleblowing channel, to raise concerns in relation to real or suspected corruption incidents or inadequacies.TF Value-Mart encourage open discussion in a constructive and non-bureaucratic way and will not permit retaliation of any kind against any Employees and/or Associated Persons for making good faith reports about actual or suspected violation of this policy.

6.1
Anti-Bribery and Anti-Corruption Guidance and Whistleblowing

If Employees and/or Associated Persons become aware of any actual or suspected breach of this policy, they must report this to TF Value-Mart’s whistleblowing committee as follow:-

Whistleblowing Committee

Ho Mun Hao, Chief Executive Officer

Anthony Lee, Chief Financial Officer

Sim Sook Yee, Senior Manager, Merchandising

Robin Ho, Finance Manager

Zirman, Group Operations Manager

Joanne Lee, Head of Human Resource

Whistleblowing Email ethics@tfvaluemart.com.my
Whistleblowing Hotline 012-747 5350
Employees and/or Associated Persons shall report all complaints in good faith and legitimate manner if they are aware of or suspect any wrongdoing, including but not limited to:-
  1. Corruption (bribery, kickbacks, conflicts of interest);
  2. Asset misappropriation (physical assets, information, inventory, cash);
  3. Fraudulent statements (financial, non-financial in nature);
  4. Action or attempted action to defraud TF Value-Mart;
  5. Breach of any statutory laws and regulations;
  6. Breach of any policy and standard operating procedure (anti-corruption, code of conduct); or
  7. Suppress or conceal and/or attempt to suppress or conceal any information relating to the above.
Any whistleblowing/reporting in good faith should contain, to the extent possible, the following:
Details of the person(s) involved
Type and details of allegation
Time, Location and Date
Other relevant information
Any supporting evidence and documentation

All concerns reported will be taken seriously, treated in confidential manner and investigated immediately. Proper investigation will be taken place followed by appropriate action taken (if any). Your anonymity will be protected unless disclosure is required by law pursuant to an investigation or legislation, but you may be required to provide a statement as supporting evidence to any investigation.

Anyone who makes any malicious, scandalous or vexatious report, and particularly if he/she persist with such untrue allegations, they will be subject to TF Value-Mart’s disciplinary actions.

If any of the relevant parties has any doubts or queries with regard to the application of this policy, the relevant party may also contact the Integrity Team vide <azmal@tfvaluemart.com.my>.

7.
Enforcement for Non-Compliance

TF Value-Mart regard acts of bribery and corruption seriously and will take appropriate actions in the event of non-compliance of this policy.

For Employees, non-compliance of this policy may lead to disciplinary action, up to and include dismissal.

For Associated Persons, non-compliance of this policy may lead to termination of contract/engagement and claim for damages.

8.
Training and Communications

This policy is a public document which shall be communicated to all our Employees and Associated Persons. All our Employees and Associated Persons must read and understand TF Value-Mart’s position on anti-bribery and anti-corruption.

Adequate training on TF Value-Mart’s anti-bribery and anti-corruption approach shall be provided to our Employees and Associated Persons.

9.
Anti-Bribery and Anti-Corruption Compliance Function
9.1
Setting up of Integrity Team

TF Value-Mart has established and will continue to maintain an Integrity Team to be responsible for all anti-bribery and anti-corruption compliance matter.

The Integrity Team is adequately equipped to act effectively against bribery and corruption in the following manner:-

  1. Provide advice and guidance on anti-corruption compliance programme and issues relating to bribery and corruption;
  2. Take appropriate steps to ensure that there is adequate monitoring, measurement, analysis and evaluation of the anti-corruption compliance programme; and
  3. Report on the performance of the anti-corruption compliance programme to the management and Audit Committee regularly.

The Integrity Team is staffed with persons who have the appropriate competence, status, authority and independence. TF Value-Mart will ensure appropriate resources be provided for effective operation of the anti-corruption compliance programme.

The lines of authority for the Integrity Team tasked with responsibility for overseeing the anti-bribery and anti-corruption compliance programme shall be directly to the Audit Committee.

Currently, the Integrity Team comprise:-

Integrity Team

Simon Chong, Operations Directors

Tay Saw Hoon, Merchandising Director

William See, Financial Controller

Azmal Azfanizal, HR Manager

Integrity Email azmal@tfvaluemart.com.my
Integrity Hotline 013-438 3435
10.
Clarifications

Should you require further clarification with regard to this policy, you should consult the following:-

This policy is applicable to all TF Value-Mart’s Employees. Joint Venture companies in which TF Value-Mart is a non-controlling shareholder or partner and associated companies are encouraged to adopt this policy as the bare minimum or similar principles and standards as part of their anti-corruption framework.

The term “TF Value-Mart”, “the Company”, “we”, “us” or “our” when used in this policy shall refer to TF Value-Mart Sdn. Bhd. and its subsidiaries, if any, and the term “you” or “your” shall refer to each of our Employee or Associated Person individually and in the case of Associated Persons, including any entity which is controlled by our Associated Persons, unless the context indicates otherwise.

Person In Charge’s Name

Joanne Lee

Email joanne.lee@tfvaluemart.com.my
Contact Number 016-412 2319
11.
Confirmation by TF Value-Mart’s Employees

Effective from the date of this policy, all Employees of TF Value-Mart shall confirm that they have read, understood and will abide by this policy. A copy of this confirmation shall be documented and retained by HR Department for the duration of employment.

12.
Independent Audit

TF Value-Mart is committed to making the anti-bribery and anti-corruption effort as a continuous effort to maintain the reputation and standards of TF Value-Mart.

TF Value-Mart shall from time to time, commission an independent audit to monitor, review, improve and assess performance, efficiency and effectiveness of ongoing anti-bribery and anti-corruption efforts by TF Value-Mart. The results of any audit, risk assessment, review of control measures and performance shall be reported to Audit Committee and acted upon accordingly.

13.
Policy Review

The management of TF Value-Mart reserve the rights to update, amend, revise, modify, suspend or terminate this policy at any time, with or without notice, to ensure its adequacy in implementation and enforcements.