1.0      Introduction

ZBN Group Holdings Sdn Bhd ("ZBNGH" or "Company") has issued an Anti-Bribery and Corruption Policy (ABC) which stipulates a firm stance "from the top side" of all corruption and responsibility practices of the Associated Parties (refer to Section 3 below) in compliance with and upholding ZBNGH's zero-tolerance stance on corruption and corruption.

The ABC policy also refers to the Code of Conduct and Ethics, Gift and Entertainment Policy, Policy on Contributions and granting of prescribed Information. The requirements for these policies have been consolidated into the documents below.


2.0      Scope

This ABC policy involves all ZBNGH entities. This ABC policy applies to all directors, employees (whether, fixed or permanent), trainees, staff borrowed, casual workers, agency staff, volunteers, industry trainees, ZBNGH agents.

ZBNGH also urges all partners, contractors, subcontractors, vendors, suppliers, service providers, consultants, representatives and anyone else who is doing work or service on behalf of the Company, or anyone connected to ZBNGH, to endorse this ABC Policy while doing the relevant work or services.


3.0      Definition

ZBNGH means ZBN Group Holdings

Corruption refers to the action of giving corrupt permission, giving, agreeing to give, promise, offer, request, accept or agree to receive a feed.

Associate means all directors, employees (whether temporarily, fixed, or fixed period, trainee, staff borrowed, casual workers, agency staff, volunteers, industrial trainers, and ZBNGH agents and partners, contractors, subcontractors, vendors, suppliers, service providers, consultants, representatives and all those who do work or services to ZBNGH.

Corruption means giving or receiving any cash-shaped feed or reward or something valuable as an inducement to commit acts related to its official duties.

Feed means:

  1. monies, donations, gifts, loans, fees, rewards, valuable collateral, property or interest on property whether movable or not, financial benefits or any other similar benefits;
  2. any position, greatness, employment, contract of employment or service, and all agreements to provide employment or provide services in any affordability and capacity;
  3. any payment, discharge, fulfillment or settlement of loans, obligations or other liabilities, whether in whole or in part;
  4. any type of valuable consideration, discount, commission, rebate, bonus, deduction or percentage;
  5. any act of delay to enable claim or value equivalent to money or valuables;
  6. any type of service or other help, including protection against penalties or inability imposed or feared or from any act or proceeding of a disciplinary, civil or criminal nature, whether or not committed yet, and includes the use or refrain from using any official right or obligation; And
  7. any offer, pledge or promise, whether conditional or unconditional, to provide a feed in the sense of any paragraph (a) to (f).


4.0      Policy Statement

ZBNGH has a zero-tolerance stand against corruption and corruption practices.

ZBNGH is committed to acting professionally, fairly and with integrity in all its business and relationship dealings, and is committed to implementing and enforcing a system that ensures corruption and corruption is prevented.

In particular, the Board and Senior Management of ZBNGH will not condone or agree to any Associate:

  1. request corrupt, accept or agree to receive any gratification either for himself or any other person; or
  2. corruptly grant, agree to give, promise or offer a feed to any person for the benefit of himself or another person, whether with the intention of obtaining or retaining business or any advantage in doing business for the Company.

The Company will uphold all legal and regulatory requirements relating to anti-corruption and corruption according to all jurisdictions in which it operates.

The Company takes seriously any violation of the ABC Policy and will take strict and appropriate action. These actions include but are not limited to, re-evaluating employment or appointment, disciplinary action, dismissal, termination of third party contractors/service providers from pursuing business dealings etc., as well as reporting any offences to the relevant authorities, consistent with the relevant legal and regulatory requirements.


5.0      Gifts and Entertainment

Acceptance and award of prizes and entertainment are subject to the Code of Conduct & Ethics and Gifts & Entertainment Policy set by the Company, where certain approvals must be obtained prior to issuing any particular type or amount of expenditure to provide gifts and entertainment, as well as to receive gifts and entertainment.

All employees are required to make a thorough assessment and ensure that acceptance of gifts or entertainment will not result in conflicts of interest.

All ZBNGH employees are strictly prohibited from receiving or offering the following gifts and entertainment:

  1. any form of gift and/or entertainment such as, or looks like, insinuating, frequently or excessively, taking into account all relevant facts and circumstances;
  2. any sum or its value equal to money (gift, voucher, etc.);
  3. any form of gift and/or entertainment in return for action from the Company or actions for the benefit of the Company; And
  4. any form of gift and/or other entertainment for purposes that violate Malaysian law, for example corruption.

Without prejudice to the above, all employees must immediately declare any gift or entertainment exceeding RM100 which the give or receive. Gifts or entertainment received without the approval of the relevant authority in ZBNGH, must be refunded to the person giving the gift or entertainment.


6.0      Donations and Sponsorships

All donations and sponsorships made by the Company for charitable purposes ("Donations") are subject to the Company's Donation Policy and Expenditure Approval Application Policy which provides, among others:

  1. No political donation is allowed
  2. Due scrutiny should be done on the recipients to determine that they have a good reputation
  3. All donation applications must be assessed by the Marketing and Communications Division and approved by the authorities in accordance with ZBNGH Donation Policy


7.0       Responsibilities and Commitment

(i)      The Board of Directors of the Company and its Power of Office

  • Monitor and establish policies that assert "standing from the top level" to maintain the highest levels of integrity and corporate ethics, in compliance with applicable legal and regulatory requirements regarding the prevention of corruption and corruption;
  • Manage the principal risks of corruption/corruption and whistleblowing cases to the Company; And
  • To receive and review reports on the implementation and effectiveness of the ABC Policy on an ongoing basis.

(ii)     Senior Management of the Company

  • To promote a culture of integrity within the Company;
  • Ensuring high levels of integrity and ethics and full compliance with all legal and regulatory requirements regarding anti-corruption and corruption;
  • Managing corruption/corruption risks associated with the Company effectively;
  • Ensuring that adequate and clear policies, procedures and control systems have been set to minimize and avoid the opportunity of corruption and corruption within the Company and to take action on corruption and corruption incidents whether suspected or confirmed to occur within the Company;
  • Encourage the use of appropriate whistleblowing channels and others in relation to any suspected or absolutely occurring corruption incidents;
  • To formulate communication plans and training programs based on the Company's policies and commitment to anti-corruption and corruption for the relevant internal and external parties;
  • Act on and report to the Board on any audit results, review of risk assessment, control measures and performance related to anti-corruption and corruption compliance programs.

(iii)     Compliance & Regulatory Department

Ethics and Integrity Officers (EIO) appointed from the Compliance & Regulatory Department must handle all matters relating to anti-corruption and corruption including providing advice and guidance to employees and business partners in connection with anti-corruption and corruption compliance programs, as well as arranging and monitoring the implementation of ABC Policies, taking into account the Company’s risk assessment relating to corruption.

EIO within the Company’s Compliance & Regulatory Department can be contacted via

 (iv)   Associates

  • Comply with and uphold ZBNGH's zero tolerance stance on corruption and corruption;
  • Comply with ABC Policy;
  • To raise concerns about wrongful behavior or acts as soon as possible through various communication channels including what has been set out in the Company's Whistleblowing Policy, which is the best channel for highlighting all issues.


8.0      Risk Assessment

The Company will assess the risk of corruption/corruption against the entire Operations of the Company at least once in two (2) years and when required (including when there are changes to the law, changes in the business of the Company or the existence of circumstances in which risk assessment is required) to identify, analyse, evaluate and establish key actions necessary to mitigate the risks of corruption/internal and external corruption identified.

Senior Management will review the Company's risk assessment report and recommend improvements to the Company's policies and procedures in combating corruption/corruption. The Suspicious risk assessment report will be submitted to the Board of Directors of the Company for review.


9.0      Due Disparity

To ensure that the Associated Party also adopts HLBG's zero tolerance stance on corruption and corruption, the Bank will conduct reasonable care to assess the integrity of the Associated, including reviewing the background and/or verification of documents and/or conducting interviews, before forging any formal contact with them and periodically thereafter.


10.0    Conflicts of Interest

The Company endeavors to ensure that there is no conflict of interest that will affect the interests of the Company, its shareholders, customers and other stakeholders through identification, prevention and management of conflicts of interest.

All Associated Parties are required to declare all personal interests belonging to him or individuals connected there with him regarding any decision or matter relating thereof to the Company involving himself.


11.0    Whistleblowing Reporting Channels and Policies

Internal and external parties are encouraged to voice concerns relating to corruption/corruption incidents either true or suspected of occurrence or lack of anti-corruption and ZBNGH corruption compliance programs as soon as possible.

Whistleblowing Policy Company protects the whistleblower's identity, as well as protects whistleblowers from retaliation and adverse actions on employment, as long as the disclosure is made in good faith. Where necessary, the Company will report information on corruption incidents and corruption to the relevant authorities.


12.0    Revision, Monitoring and Enforcement

            (i) Revision

The Internal Audit Department will review the Company's anti-corruption and corruption compliance programs and measures to assess the level of compliance, performance, efficiency and effectiveness. The audit reports will be presented by the Internal Audit Department to the Company's Board Audit Committee for review and subsequently reported to the Board for full board consideration/review.

The Compliance & Regulatory Department will conduct periodic reviews on the implementation and compliance of the Company against the ABC Policy. The reports will be presented by the Compliance & Regulatory Department to the Board Risk Management Committee of the Company for review and reported to the Board.

(ii) Monitoring

All Heads of Departments will monitor their staff's performance in relation to this policy and report any non-compliance. The non-compliance report will be tabled by the Compliance Department to the Risk Management Committee of the Board of Directors of the Company/ The Board for review.

(iii) Enforcement

The Company will take appropriate disciplinary action against the Associated Associates found not to comply with the ABC Policy.

If gaps or deficiencies are detected during policy breaches, review processes, or when there are new developments in the industry, laws and regulations, improvements to the Company's policies and procedures will be considered and/or improved immediately.


13.0   Training and Communication

The Company has training programs and communication plans that are in line with the policy and commitment to anti-corruption and corruption for all relevant parties.