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- Purpose
This policy outlines the commitment of Triangle Worldwide Sdn Bhd to conducting business with integrity, transparency, and in full compliance with all applicable laws and regulations related to anti-bribery and corruption. It aims to ensure that all employees, agents, contractors, and stakeholders understand their responsibilities in preventing and reporting any form of bribery or corruption in our operations. - Scope
This policy applies to all employees, officers, directors, agents, contractors, and any other third parties acting on behalf of Triangle Worldwide Sdn Bhd, regardless of their location. It covers all activities related to the logistics industry, including but not limited to freight forwarding, warehousing, customs brokerage and transportation services. - Policy Statement
Triangle Worldwide Sdn Bhd strictly prohibits all forms of bribery and corruption, whether direct or indirect. This includes the offering, giving, soliciting, or receiving of any form of bribe, kickback, or other improper advantage in order to secure or retain business, influence decisions, or gain any undue benefit. - Definitions
- Bribery refers to the act of offering, giving, receiving, or soliciting anything of value (such as money, gifts, favours, or services) with the intention of influencing a decision, action, or behaviour in an improper manner. This includes attempts to sway the judgment or conduct of individuals in positions of authority or power, with the goal of obtaining an unfair advantage or securing a favour in business or governmental dealings.
- Corruption involves the abuse of power or authority that has been entrusted to an individual, typically for personal or private gain. This can include the manipulation of processes, such as diverting funds, awarding contracts unfairly, or engaging in fraudulent activities, for the benefit of the individual or a third party. Corruption undermines trust and the integrity of systems, processes, and institutions, leading to significant ethical, legal, and financial repercussions.
- Facilitation payments are small, often informal payments made to expedite or secure the performance of routine governmental or administrative tasks. These are typically used to overcome bureaucratic delays or to speed up processes that should be carried out in the normal course of duty. While they may be seen as common in certain environments, they are considered unethical and, in many jurisdictions, are illegal, as they may pave the way for larger-scale corrupt practices.
- In the context of Triangle Worldwide Sdn Bhd, third parties encompass any individuals, entities, or organisations that interact with the company through its various business activities. This includes suppliers, customers, contractors, consultants, agents, joint venture partners, and others who may engage with the company in any form. Third parties are often integral to the company’s operations, and their actions, whether intentional or inadvertent, can have an impact on the company’s compliance with ethical standards, laws, and regulations.
- Responsibilities
- Management: Ensure compliance with this policy and foster a culture of integrity.
- Employees: Understand and adhere to this policy, reporting any breaches.
- Third Parties: Abide by this policy when acting on behalf of Triangle Worldwide Sdn Bhd.
- Prohibited Conduct
Employees and third parties acting on behalf of Triangle Worldwide Sdn Bhd must not:- Offer, promise or give bribes.
- Request, agree to receive or accept bribes.
- Make facilitation payments unless there is a risk to personal safety.
- Engage in corrupt practices or fraudulent activities.
- Offer or accept gifts or hospitality that could influence business decisions.
- Gifts, Hospitality, and Entertainment
All gifts, hospitality, and entertainment must:- Be modest and reasonable and do not influence or appear to influence decision-making.
- Be recorded accurately in the company’s records.
- Be pre-approved if exceeding a specified threshold.
- Due Diligence
Triangle Worldwide Sdn Bhd will conduct due diligence on third parties, including suppliers, contractors, and agents, to ensure they comply with anti-bribery and corruption laws. - Reporting and Whistleblowing
Employees and third parties are encouraged to report any concerns or breaches of this policy. Reports can be made anonymously via email to [email protected]. Triangle Worldwide Sdn Bhd guarantees confidentiality and protection against retaliation for whistleblowers. - Record-Keeping
All financial transactions, gifts, and hospitality must be documented and maintained for audit purposes. Accurate and transparent records are essential to demonstrate compliance with this policy. - Training and Awareness
Triangle Worldwide Sdn Bhd will provide regular training to employees and relevant third parties to ensure they understand this policy and their responsibilities. - Consequences of Non-Compliance
Non-compliance with this policy will result in disciplinary action, including termination of employment or contracts. It may also lead to legal consequences, including fines and imprisonment, under applicable laws. - Monitoring and Review
This policy will be reviewed periodically to ensure it remains relevant and effective. Audits and compliance checks will be conducted regularly to identify and address any risks. - Governing Laws
This policy is governed by the laws of Malaysia, including the Malaysian Anti-Corruption Commission Act 2009 (MACC Act) and any other applicable regulations. - Contact Information
For questions or concerns regarding this policy, please contact Ms Joyce Godwin at [email protected].
- Purpose
Acknowledgement
All employees and third parties must acknowledge that they have read, understood, and agree to comply with this policy.
Effective Date : 16th January 2025
Approved by : Marc Zuriel Philip – Chief Executive Officer