1. Definitions
   1. Personal gift: Cash, movable and immovable assets, vehicles, free fares, shares, lottery tickets, travel facilities, entertainment, services, club memberships, any forms of discount or commission, hampers, jewelleries, decorations, souvenirs, or any other valuable items given to or received by an individual, by his/her spouse or by any other third party acting on behalf of the individual.
   2. Corporate gift: A gift given from one organisation to another, to and from appointed representatives of each. The gifts are given openly, with the implicit or explicit approval of the management on both sides. Examples of corporate gift are corporate diaries, table calendars, pens, and notepads.

2. Purpose of the Gifts Policy
   1. Gifts present a bribery risk with negligence, inexperience and ignorance to the potential risk of corruption adding to the likelihood of gifts being used as a means of bribery.
   2. Gifts may be used by corrupt third parties to manoeuvre the company’s employees to a position of obligation and prepare the way for a corrupt act.
   3. They may also be used by employees to corruptly build favours with prospective clients. Inappropriate gifts given to a potential client may also cause offence or infringe on the client’s own rules which could lead to exclusions from future business dealings.
   4. The purpose of this gift policy is to provide guidance to its users on what the company considers to be acceptable and unacceptable gifts, as well as provide guidance on the appropriate procedures to take when giving or receiving gifts from external parties.

3. Scope
   1. This policy is applicable to all company staff, including but not limited to the CEO, directors, employees, contract staff and its agents.

4. Giving Gifts to External Parties
   1. Policy
      1. The only form of gift giving allowed to external parties is a corporate gift.
      2. The giving of gifts of any kind to government servants is prohibited without prior approval from the CEO and IM.
      3. All staff are prohibited from giving cash gifts or providing loans for external parties in the course of performing their duties with the company.
   2. Procedure
      1. All requests for giving of gifts must be submitted to the CEO along with a completed gifts application form for approval.along with a completed gifts application form for approval.
      2. The CEO will call upon the IM to assist with the process of the gift applications.
      3. All approvals must be given in writing (including email) by the CEO and the IM before proceeding.
      4. The IM will record all requests and decisions made in the Gifts & Hospitality Log, along with the reason for giving the gift.
      5. On submission of expense claims, items for gifts must be marked as such, for recording by the Finance department when processing the claim.
   3. Review and inspection of compliance to policies and procedures
      1. The IM is to receive a monthly report from the Finance Department, detailing gifts and hospitality claims.
      2. The IM will conduct monthly reviews using these reports to ensure that:
      3. The total value of gifts and hospitality given to any single recipient does not exceed RM1,000 within the last 12 months, or is suspiciously excessive.
      4. The reasons for giving gifts valued greater than the stated limits are appropriate and are business related.
      5. The gift(s) given to an individual is not likely to create a sense of obligation towards the giver and the company.
      6. Risk areas are to be identified and recorded on the Risk Log for inspection.

5. Receiving Gifts from External Parties:
   1. Policy
      1. The receiving of personal gifts by employees from external parties is strictly prohibited.
      2. The delivery of gifts, either personal or corporate, to the personal addresses of employees is strictly prohibited.
   2. Procedure
      1. The receiving of corporate gifts valued equal to or less than RM50 per gift must be reported to the IM via email who will record it in the Gifts & Hospitality Log. Unless notified otherwise by the IM, the recipient may keep the gift, unless it is a hamper (see 5.2.4 for guidance on hampers).
      2. For gifts received valued more than RM50, approval from the IM must be secured to keep the gift:
         1. Report the gift to the IM via email, along with the justification for keeping the gift (if any).
         2. The IM will notify the recipient of the final decision.
         3. Where a gift cannot be kept, the IM will return refused gifts to the gift giver.
         4. The IM will record all requests and decisions made in the Gifts & Hospitality Log, along with the reason for keeping the gift.
      3. If a gift is delivered to the personal address of an employee, the gift must be surrendered to the IM. The IM will then return the gift to the giver, with a gift refusal letter explaining the Company policy on gifts.
      4. Hampers of any value from external parties must be delivered to the HOD for distribution amongst company staff. If the HOD is not available, they should be passed to the IM or CEO. Hampers delivered directly to an employee’s home address are to be brought to the office and passed to the HOD/IM for distribution.
      5. The IM will send records of all gifts received by staff to their respective HODs. The HODs will maintain records of this and monitor for risk areas in their departments. If an employee’s or a department’s activities become a cause for concern, this must be reported to the IM.
   3. Review and inspection of compliance to policies and procedures
      1. The IM is to receive a monthly report from the Finance Department, detailing gifts and hospitality claims.
      2. The IM will conduct monthly reviews using these reports to ensure that:
         1. The total value of gifts and hospitality received by a single recipient did not exceed RM1,000 in the last 12 months, or is suspiciously excessive.
         2. The reasons for receiving gifts valued greater than the stated limits are appropriate and are business-related.
         3. The gifts received are not likely to create a sense of obligation towards the giver.
      3. Risk areas are to be identified and recorded in the Risk Log for inspection.

6. Hospitality Policy & Procedures
   1. Definitions
      1. Hospitality: Cordial reception or disposition towards an individual, which might include entertaining guests in resorts, restaurants, conventions, concerts, sporting events and other special occasions.
   2. Purpose of a Hospitality Policy
      1. Hospitality presents a bribery risk with negligence, inexperience and ignorance of the potential risk of corruption adding to the likelihood of hospitality being used as a means of bribery.
      2. Hospitality may be used by corrupt third parties to encourage a sense of obligation towards the giver and to prepare the way for a corrupt act. Some forms of hospitality such as hostess services also present a risk to the company as they may be used a basis for blackmail and should never be accepted by staff acting on behalf of the company.
      3. Hospitality may also be utilised by employees to corruptly build favours with prospective clients. Inappropriate hospitality given to a potential client may also cause offence or infringe on the client’s own rules which could lead to exclusion from future business dealings.
      4. The purpose of this hospitality policy is to provide guidance to its users on what the company considers to be acceptable and unacceptable hospitality, as well as provide guidance on the appropriate procedures to take when giving or receiving gifts from external parties.
   3. Scope
      1. This policy is applicable to all company staff, including but not limited to the CEO, directors, employees, contract staff and its agents.
   4. Policy
      1. Company staff are prohibited from giving and receiving the following activities and services:
         1. Drugs
         2. Gambling
         3. Hostess entertainment
         4. Karaoke
         5. Liquor
         6. Massage
         7. Unregulated violent sports
         8. Any other activities prohibited under HR policies and procedures in practice by RidPest
      2. Giving Hospitality to External Parties
         1. Policy
            1. Hospitality provided must not be illegal or of a nature which could be regarded as immoral or offensive to stakeholders.
            2. The giving of hospitality is only permitted by sales staff or senior management (HODs or above). Pre-approval is not required if:
               1. It is business-related.
               2. The cost of the hospitality provided does not exceed RM150 per head.
               3. Hospitality is not provided to spouses and other non-business guests.
               4. Written approval is required from the IM or the CEO if:
               5. The cost of the hospitality provided is more than the stated limits.
               6. Spouses or any non-business guests of the invitee(s) are included.
               7. The activity is not directly related to business. For example, sponsored leisured trips or shopping.
               8. All hospitality given must be supported by receipts.
         2. Procedure
            1. Hospitality that fulfils the requirements as listed in 6.4.1.1 and 6.4.2.1 does not require approval and may proceed as usual.
            2. Requests for the giving of hospitality that does not fulfil the requirements as listed in 6.4.1.1 and 6.4.2.1 must be forwarded to the IM or CEO for approval.
            3. The IM will record all requests, approvals and denials in the Gifts & Hospitality Log.
            4. When hospitality is given, all staff are to obtain and keep receipts as supporting documents.
            5. On submission of expense claims, items for gifts and hospitality must be marked as such, for recording by the Finance department when processing the claim.
            6. The claims must be submitted to the IM or CEO for verification, before being forwarded to the Finance department.
            7. The Finance department will reimburse the staff member accordingly.
         3. Review and inspection of compliance to policies and procedures
            1. The IM is to receive a monthly report from the Finance Department, detailing gifts and hospitality claims.
            2. The IM will conduct monthly analysis using these reports to ensure that:
               1. The total value of gifts and hospitality given to any single recipient did not exceed RM1,000 in the last 12 months, or is suspiciously excessive.
               2. The reasons for giving hospitality exceeding applicable thresholds are appropriate and are business related.
               3. The hospitality given to an individual is not likely to create a sense of obligation towards the giver and the company.
            3. Risk areas are to be identified and recorded in the Risk Log for inspection.
         4. Receiving Hospitality from External Parties
            1. Policy
               1. Hospitality received by staff acting as representatives of the company must not be illegal or of a nature which could be regarded as immoral or offensive to stakeholders.
               2. The receiving of hospitality is permitted provided that:
                  1. It is business-related.
                  2. The cost of the hospitality received is not more than RM150 per head.
                  3. Hospitality is not provided to spouses and other non-business guests.
               3. Written approval is required from the IM or the CEO if:
                  1. The cost of the hospitality received is more than the stated limits.
                  2. Spouses or any non-business guests of the invitee(s) are included.
                  3. The activity is not directly related to business. For example, sponsored leisure trips or shopping.
            2. Procedure
               1. Receiving hospitality that fulfils the requirements as listed in 6.4.1.1 and 6.4.2.1 does not require approval and may proceed as usual.
               2. Requests for the receiving of hospitality that do not fulfil the requirements as listed in 6.4.1.1 and 6.4.2.1 must be forwarded to the IM or CEO for approval.
               3. The IM will record all requests, approvals and denials in the Gifts & Hospitality Log.
            3. Review and inspection of compliance to policies and procedures
               1. The IM will conduct monthly reviews on records to ensure that:
                  1. The total value of hospitality and gifts received by a single recipient did not exceed RM1,000 in the last 12 months, or is suspiciously excessive.
                  2. The reasons for receiving hospitality exceeding applicable thresholds are appropriate and business-related.
                  3. The hospitality received is not likely to create a sense of obligation towards the giver.
               2. Risk areas are to be identified and recorded in the Risk Log for inspection.

7. Charitable Donations And Sponsorship Policy
   1. General Definitions:
      

      Corruption	The misuse of entrusted power for private gain
      Bribery	The giving or receiving of money, a gift or other advantage, as an inducement to do   something that is dishonest, illegal or a breach of trust in the course of doing business
      CEO	Chief Executive Officer
      IM	Integrity Manager
      HOD	Head(s) of Department(s)
      Stakeholders	Individuals or groups concerned with, or affected by company policy and practice, including, but not limited to, employees, customers, government bodies, suppliers, contractors
      External Parties	Organisations or individuals external to RidPest Sdn. Bhd. who can or may exert influence on the organisation by gift giving and / or hospitality.
      Written approval	Approval given by letter, email or text message (SMS) in a form which can be clearly   identified as originating from the authoriser, and can be retained, archived   and produced on demand.

8. Charitable Donations And Sponsorship Policy & Procedures
   1. Charitable Donations: donations, financial or in kind, given for the purpose of supporting a worth and needy cause, through a registered charity. These include loans, gifts of property, services, sponsorship of tables at events, advertising or promotional activities endorsing a charitable organisation. The release of employees during working hours from the employer to the charity is also included in the definition.
   2. Sponsorship: Financing part of a project or event, carried out by another person or organisation, in return for advertisement
   3. Purpose
      1. Charitable contributions can present a bribery risk as it involves payments made to a third party without tangible return and may be used as a subterfuge or route for bribery. Donations can be steered for corrupt purposes to ‘front’ charitable, sporting or philanthropic organisations or used to create undue influence such as donating to a favoured cause of a decision maker or customer. Donations made through an intermediary present further risk as they can be subject to less control and follow-up. If the company has a foundation or trust it may fall outside the company’s Programme, donations may be made without reference to the company and might be seen by stakeholders as undue influence on a decision maker for a potential contract.
      2. Sponsorships, unlike charitable contributions, are made for business objectives and are usually for brand or reputation management purposes. They can present a bribery risk as it involves payments made for services or benefits which are often difficult to measure and track. Sponsorships can be subject to kickbacks; funds can be steered for corrupt purposes to ‘front’ charitable, sporting or philanthropic organisations or used to create undue influence such as sponsoring a favoured cause of a decision maker or a customer. Hospitality is often tied to sponsorships and can be inappropriate when the value of tickets and entertaining are high, for example major sporting events. For these reasons, the company should have a precise documented policy for sponsorships, supported by transparent selection criteria, review procedures and detailed controls including evaluation of sponsorships made.
      3. The purpose of this charitable contributions & sponsorships policy is to provide guidance to its users on the appropriate procedures to take when a request for charitable contributions or sponsorships is made.
   4. Policy
      1. Charitable donations and sponsorships which are made to secure a business deal or awards are prohibited, no matter what form they take, and whether they are made directly or indirectly.
      2. If the payment is to a political party, either directly to party funds or individuals known to be engaged in political activities, or indirectly via sponsorship of events, meals, tables or by subsidising of items, or by charitable donations to organisations or individuals with known political connections where there is a likelihood the funds will be used for political purposes, please see the Political Contributions Policy.
      3. Sponsoring of award events, including payment for dinner tables, where sponsorship may be linked to receiving of the award, is prohibited.
      4. An accurate record of all donations and sponsorships must be maintained.
      5. All charitable donations and sponsorships must follow the official company procedure.
   5. Procedure
      1. All individuals or organisations wishing to ask for a contribution must fill out a Charitable Donations and Sponsorships Application Form and deliver it to the IM either via e-mail or in person
      2. Upon receipt of a Charitable Donations and Sponsorships Application Form, the IM must conduct background checks, covering the following aspects:
         1. The recipient organisation is authentic
         2. The IM has all the relevant information pertaining to the application
         3. The contribution is not being made to secure a business deal
         4. The recipient organisation is not a political party or related to one – to be checked by the IM
      3. Upon completion of the background checks, the IM will present the application to the CEO for approval:
         1. If the application is rejected, the IM must send a refusal letter to the requestor within 14 days.
         2. If the application is approved, the IM must forward the decision to the Finance Department for appropriate payment arrangements to be made.
      4. Payment delivery to be performed by the Finance Department.
      5. On payment, a receipt must be obtained, recorded and archived.
      6. For payments larger than RM500, a brief report, including pictures pertaining to the event/organisation, must be presented to the IM.
   6. Approvals & Authority Limits
      

      Approvals & Purpose	Authority Limit / Turnaround time	Responsible party
      Conduct background checks	3 days	IM
      Approvals	2 weeks	CEO
      Provision of funds for donations/sponsorships	2 days	Finance Department
      Maintain record of donations/sponsorships	On-going	Finance Department

9. Political Contributions Policy
   1. General Definitions:
      

      Corruption	The misuse of entrusted power for private gain
      Bribery	The giving or receiving of money, a gift or other advantage, as an inducement to do   something that is dishonest, illegal or a breach of trust in the course of doing business
      CEO	Chief Executive Officer
      IM	Integrity Manager
      HOD	Head(s) of Department(s)
      Stakeholders	Individuals or groups concerned with, or affected by company policy and practice, including, but not limited to, employees, customers, government bodies, suppliers, contractors
      External Parties	Organisations or individuals external to RidPest Sdn. Bhd. who can or may exert influence on the organisation by gift giving and / or hospitality.
      Written approval	Approval given by letter, email or text message (SMS) in a form which can be clearly   identified as originating from the authoriser, and can be retained, archived   and produced on demand.

   2. Political Contributions Policy & Procedures
      1. Definitions for Political Contributions
         1. Political Contributions: Contributions, financial or in kind, given for the purpose of supporting a political cause. This includes loans, gifts of property, services, sponsorship of tables at events, advertising or promotional activities endorsing a political party. The release of employees during working hours from the employer to undertake political campaigning or to stand for office is also included in the definition.
      2. Purpose
         1. Political contributions can be a legitimate way for a company to support the democratic process by providing financial and other support to assist political parties to carry out their role but laws and practices can vary between countries. Political contributions can be vulnerable to abuse with companies using contributions to gain undue influence to win contracts or shape legislation favourable to their business. Some companies prohibit all political contributions because of the risks attached and the potential to damage reputation.
         2. The purpose of this political contributions policy is to provide guidance to its users on the appropriate procedures to take when a request for political contributions is made.
      3. Policy
         1. No payments to political parties are permitted, either directly to party funds or individuals known to be engaged in political activities, or indirectly via sponsorship of events, meals, tables or by subsidising of items, or by charitable donations to organisations or individuals with known political connections where there is a likelihood the funds will be used for political purposes.
      4. Procedure
         1. Requests for contributions to political parties are to be sent to the IM for processing.
         2. The IM will arrange for a letter to be sent to the applicant informing them of the company policy and politely refusing the request.
         3. The application, letter and other information of the event will be logged by the IM for future reference

10. Facilitation Payments Policy
    1. General Definitions:
       

       Corruption	The misuse of entrusted power for private gain
       Bribery	The giving or receiving of money, a gift or other advantage, as an inducement to do   something that is dishonest, illegal or a breach of trust in the course of doing business
       CEO	Chief Executive Officer
       IM	Integrity Manager
       HOD	Head(s) of Department(s)
       Stakeholders	Individuals or groups concerned with, or affected by company policy and practice, including, but not limited to, employees, customers, government bodies, suppliers, contractors
       External Parties	Organisations or individuals external to RidPest Sdn. Bhd. who can or may exert influence on the organisation by gift giving and / or hospitality.
       Written approval	Approval given by letter, email or text message (SMS) in a form which can be clearly   identified as originating from the authoriser, and can be retained, archived   and produced on demand.

    2. Definitions for Facilitation Payments
       1. Facilitation Payments Policy & Procedures
       2. Facilitation Payment: A bribe paid in order to secure or expedite the performance of routine official action (such as processing government papers, issuing licences or permits, clearing goods through customs or obtaining adequate police protection) to which the company is entitled.
    3. Purpose
       1. Facilitation payments are problematic as they are illegal in most countries, including Malaysia. However, they remain widespread and may be paid on behalf of the company by agents or other similar intermediaries. The dividing line between facilitation payments and bribes is not easily drawn and can weaken the company’s ability to implement its anti-bribery Programme. The policy for facilitation payments should be aligned to the overall no-bribes policy and will provide the platform for procedures to eliminate or control such payments and to ensure that the company complies with laws whether anti-corruption or taxation. In some cases the demand for facilitation payments may be accompanied by a threat to safety or health – these are extorted payments and the company should provide guidance to employees and agents on how to handle these safely and where to get advice.
       2. The purpose of this facilitation payments policy is to provide guidance to its users on the appropriate procedures to take when a request for facilitation payment is made.
    4. Policy
       1. In accordance to Section 21 (b) of the Malaysian Anti-Corruption Commission Act 2009, the Company prohibits its employees from making any form of facilitation payment.
       2. Scope
       3. This policy applies to all departments of the company.
    5. Procedure
       1. When a request for a facilitation payment is made, the IM must be immediately informed by the employee, and no payment, in cash or kind, must be given
       2. Upon notification, the IM will record the incident and immediately report this to the CEO.
       3. The CEO will decide on whether to report the event to the Malaysian Anti-Corruption Commission or any other relevant authority.
       4. All incidents involving requests for facilitation payments, including decisions and any other follow ups, must be recorded and logged by the IM.

11. Declaration Of Conflict Of Interest Policy
    1. General Definitions:
       

       Corruption	The misuse of entrusted power for private gain
       Bribery	The giving or receiving of money, a gift or other advantage, as an inducement to do   something that is dishonest, illegal or a breach of trust in the course of doing business
       CEO	Chief Executive Officer
       IM	Integrity Manager
       HOD	Head(s) of Department(s)
       Stakeholders	Individuals or groups concerned with, or affected by company policy and practice, including, but not limited to, employees, customers, government bodies, suppliers, contractors
       External Parties	Organisations or individuals external to RidPest Sdn. Bhd. who can or may exert influence on the organisation by gift giving and / or hospitality.
       Written approval	Approval given by letter, email or text message (SMS) in a form which can be clearly   identified as originating from the authoriser, and can be retained, archived   and produced on demand.

    2. Declaration Of Conflict Of Interest Policy & Procedures
       1. Definitions
          1. Interest: A person’s stake or involvement in an undertaking, financial or otherwise, which may lead to prejudice and bring advantage or benefit to a person or group.
          2. Conflict of interest: A situation where a person’s private interests conflicts with the interests of the company.
          3. Spouse: A person’s partner in marriage in accordance to The Law Reform (Marriage & Divorce) Act 1976.
          4. Dependent: A person who depends on another, especially a family member, for support, aid, or sustenance, especially financial support. The definition also covers “relative” and “associate” as defined by Section 3 of the Malaysian Anti-Corruption Commission Act 2009.
       2. Purpose of a Declaration of Interest Policy
          1. The existence of conflict of interest poses a significant threat to the high integrity standard which the company upholds. Conflict of interest happens when company staff involves in business dealings, either directly or indirectly, with the company without the knowledge of the company management. Examples of conflict of interest are described below but they are by no means exhaustive:
             1. A staff member involved in a procurement process is closely related to or has beneficial interest in a supplier being considered by the company.
             2. One of the candidates under consideration in a recruitment or promotion exercise is a family member, a relative or a close personal friend of the staff member responsible for the exercise.
             3. A staff member undertaking part-time work with a contractor whom he / she is responsible for monitoring.
             4. Company staff should avoid any conflict of interest situation, or the perception of such conflicts, to protect both the company and the staff’s reputation. Staffs are prohibited from misusing their position or authority in the company to pursue their own private interests.
          2. The purpose of this declaration of conflict of interest policy is to provide guidance to its users on the company’s requirements of its staff in declaring conflicts which may arise in their official duties with the company.
       3. Scope
          1. This policy is applicable to all RidPest staff, including but not limited to the CEO, directors and other employees, throughout their employment with the company.
       4. Policy
          1. All company staff must declare his / her financial or other personal interest that may, directly or indirectly, in any matter, that raises or may raise a conflict in his / her official with the company.
          2. Frequency
             1. All company staff must complete a Declaration of Interest (DOI) forms on joining RidPest, and annually thereafter.
             2. Staff and directors shall notify the IM, project manager or relevant line manager of any further potential conflict of interest as it arises.
          3. Submission and Administration
             1. Submission
                1. All staff shall be given a DOI form on joining RidPest by IM. The form must be completed and returned to IM within 5 working days.
                2. Thereafter, IM will send the form to all staff members on an annual basis to be completed and returned within 5 working days.
                3. For projects requiring declaration of interest, the project manager will provide copies of DOI forms to all project members before the project commences. The form must be completed and returned to the project manager within 5 working days. The project manager will send the forms to the IM for storage.
                4. Where conflict of interest arises during the year or the course of a project, the staff shall notify the IM, project manager or relevant line manager immediately.
             2. Administrative
                1. All forms received by IM will be recorded and compiled.
                2. IM will provide the relevant managers and directors with updates, as and when a conflict of interest id declared, to allow for monitoring.
             3. Audit and verification
                The IM will conduct regular audits of randomly selected project to ensure that:
                1. The Declaration of Conflict of Interest policy was duly complied.
                2. The information submitted in the DOI form is complete.Should any suspicion arise, it will be recorded in the risk log and further investigation will be performed to verify the authenticity of the declaration.
             4. Information storage
                1. Electronically stored information will be password protected with restrictions to access. Any access by users will be automatically logged by the system.
                2. All paper copies will be securely stored in a locked cabinet in the IM’s personal office. Access to information will be restricted to IM and to relevant Project Managers.
             5. Sanctions for Non-compliance
                1. In the event an individual fails to comply with the submission or is proven to have provided false information, intentionally or unintentionally, he / she shall be subjected to sanctions as specified below:
                   1. Written warning;
                   2. Forfeiture of emoluments;
                   3. Deferment of salary increase;
                   4. Demotion of salary;
                   5. Demotion; and
                   6. Dismissal.

12. Integrity Pacts Policy
    1. General Definitions:
       

       Corruption	The misuse of entrusted power for private gain
       Bribery	The giving or receiving of money, a gift or other advantage, as an inducement to do   something that is dishonest, illegal or a breach of trust in the course of doing business
       CEO	Chief Executive Officer
       IM	Integrity Manager
       HOD	Head(s) of Department(s)
       Stakeholders	Individuals or groups concerned with, or affected by company policy and practice, including, but not limited to, employees, customers, government bodies, suppliers, contractors
       External Parties	Organisations or individuals external to RidPest Sdn. Bhd. who can or may exert influence on the organisation by gift giving and / or hospitality.
       Written approval	Approval given by letter, email or text message (SMS) in a form which can be clearly   identified as originating from the authoriser, and can be retained, archived   and produced on demand.

    2. Definitions for Integrity Pacts
       1. INTEGRITY PACTS POLICY & PROCEDURESIntegrity pacts were developed by Transparency International for preventing corruption in procurement. It is an agreement between the procuring company and its vendors that both will abstain from bribery, collusion and other corrupt practices when fulfilling contract terms.
    3. Purpose
       1. Procurement and contracting are highly susceptible to corruption risks. Leakages occur at all stages of procurement and contracting, including the pre-contract design, tender exercise, and enforcement of contract terms and conditions.
       2. Integrity pacts promote clean operations on the part of the procuring companies and their vendors during the execution of a project. Implementation of integrity pacts also yields other benefits such as greater transparency in contracting and enhancement of public confidence and trust.
       3. The purpose of this policy is to provide guidance to its users on the appropriate procedures when implementing integrity pacts in procurement and contracting.
    4. Policy
       1. 30.1 All procurement and contracting exercise, including new contracts and renewal of existing contracts must include an Integrity Pact as part of the agreement.
       2. 30.2 Integrity pacts are subject to the laws of Malaysia and the pacts are made in good faith by all parties involved and are legally binding.
    5. Procedure
       1. Integrity pacts must be included as part of the contractual agreement in all forms of procurement and contracting.
       2. RidPest is responsible for explaining the terms and conditions to the contractors, vendors and suppliers before the pacts are signed.
       3. The IM is responsible for ensuring that an Integrity Pact is included in all procurement and contracting agreements, and that the pact was signed by the contractors, vendors and suppliers.
    6. Sanctions for non-compliance
       1. If the vendor is found to violate terms and conditions of the Integrity Pact, RidPest may apply, in its absolute discretion, to the extent permitted by law, any or all of the following sanctions:
          1. Denial or cancellation of the contract;
          2. Fine, up to a maximum of X% of the value of the contract;
          3. Non-payment of fees/expenses;
          4. Liability for damages to RidPest, up to a maximum of 200% of the value of the contract;
          5. Forfeiture of any deposit, bid and/or performance bond; and
          6. Debarment by RidPest of selling the company and its Directors from being considered for further contracts, for such period as the company may deem appropriate.
    7. Dispute Resolution
       1. Where a dispute arises in the enforcement of terms in the Integrity Pact, all parties involved agree to an arbitration
       2. In the event of arbitration, a tribunal will be formed to settle the dispute. The tribunal shall consist of three arbitrators. Each of the two parties may select one arbitrator, with the third being an independent arbitrator mutually agreed by both arbitrators so appointed.
       3. The place of the arbitration shall be in Kuala Lumpur, at a site selected by the arbitration tribunal.
       4. The language of the arbitration shall be English.
       5. Any disputes relating to these arrangements shall be settled in accordance with the laws of Malaysia under the rules of the Malaysian Arbitration Act 2005.
       6. The ruling of the tribunal will be final and binding on all parties.
       7. The costs of arbitration will be borne equally by both parties in dispute, with charges by the tribunal quoted and agreed upon prior to commencement.

13. Whistleblowing
    1. General Definitions:
       

       Corruption	The misuse of entrusted power for private gain
       Bribery	The giving or receiving of money, a gift or other advantage, as an inducement to do   something that is dishonest, illegal or a breach of trust in the course of doing business
       CEO	Chief Executive Officer
       IM	Integrity Manager
       HOD	Head(s) of Department(s)
       Stakeholders	Individuals or groups concerned with, or affected by company policy and practice, including, but not limited to, employees, customers, government bodies, suppliers, contractors
       External Parties	Organisations or individuals external to RidPest Sdn. Bhd. who can or may exert influence on the organisation by gift giving and / or hospitality.
       Written approval	Approval given by letter, email or text message (SMS) in a form which can be clearly   identified as originating from the authoriser, and can be retained, archived   and produced on demand.

    2. Whistleblowing Policy & Procedures
       1. Definitions
          1. Whistleblowing: Disclosure by a person, to the public, or to those in authority, of mismanagement, corruption, illegality or other wrongdoing.
    3. Purpose of a Whistleblowing Policy
       1. In line with the practice of good corporate governance, RidPest is interested in ensuring that all employees are encouraged to raise concerns about potential improprieties in business conducts or other misconducts in an appropriate way.
       2. The policy aims, in compliance with Whistleblowers Protection Act 2010, to:
          1. Ensure employees are able to raise concerns without fear of suffering retribution; and
          2. Provide a transparent and confidential process for dealing with any concerns
    4. Scope
       1. This policy is applicable to:
          1. All RidPest staff, including but not limited to the directors, employees, contract staff and agents.
          2. All RidPest suppliers and contractors, including suppliers and contractors involved in the bidding of projects
          3. All RidPest consultants
          4. All RidPest customers
          5. Other stakeholders
       2. The whistleblowing policy covers the following possible improprieties in relation to RidPest:
          1. Corruption, bribery and blackmail
          2. Criminal offences
          3. Endangering the environment
          4. Endangering the health and safety of an individual
          5. Failure to comply with legal or regulatory obligations
          6. Fraud
          7. Miscarriage of justice
          8. Concealment of any of the above
    5. Policy
       1. Investigation
          1. All concerns raised via the whistleblowing hotlines will be investigated in a fair and proper manner as per the procedures set out in section 5 below
       2. Guarantee of anonymity
          1. If personal information such as name and contact details are provided by the whistleblower, only the owner/CEO and the IM will have access to these.
          2. Unless the whistleblower agrees otherwise in writing, all further reports will exclude personal details of the whistleblower. If necessary to include reference to the whistleblower, a pseudonym unrelated to the whistleblower, must be used. E.g. “Mr X” or “Ms M”.
          3. Anyone who reveals the identity of a whistleblower without prior agreement from the whistleblower will be subject to disciplinary measures, including, but not limited to, the termination of contract or removal of directorship.
       3. Assurances and protection against retaliation
          1. Definition of retaliation:
             1. Withholding of payment that is due and payable under a contract
             2. Refusal to enter into a subsequent contract
             3. Action causing injury, loss or damage
             4. Intimidation or harassment
             5. Interference with the lawful employment or livelihood of the whistleblower, including discrimination, discharge, demotion, suspension, disadvantage, termination or adverse treatment in relation to the whistleblower’s employment, career, profession, trade or business or the taking of disciplinary action
             6. A threat to take any of the actions above
          2. The whistleblower shall receive no retaliation or retribution for a report that was provided in good faith i.e. was not done primarily with malice to damage another person or the organisation.
          3. Anyone who retaliates against a whistleblower will be subject to disciplinary actions, including termination of employment, working relationship, or other legal means.
          4. A whistleblower or any person related to, or associated with, the whistleblower, who fears, or has suffered detrimental action may:
             1. Report the incident(s) to the IM.
             2. Request, in writing to the IM, for relocation of employment to another location and/or department within RidPest. Any such request shall be complied with, without prejudice, with all endeavours made by the company to act on it.
       4. Internal and external reports
          1. No personal details of the whistleblower are to be revealed in any report, unless written permission is given by the whistleblower. If necessary to include reference to the whistleblower, a pseudonym unrelated to the whistleblower, must be used. E.g. “Mr X” or “Ms M”
          2. The report should only be of details of the incident itself, and the suspect(s). Other details should be excluded.
          3. Reports are to be compiled and checked by only the IM prior to printing and distribution to ensure no personal details are revealed.
          4. Reports are only to be provided to the owner/CEO and relevant personnel performing the investigation.
       5. Information storage
          1. Electronically stored information will be password protected with access restriction. Any access by users will be automatically logged by the system.
          2. All hard copies will be securely stored in a locked cabinet in the IM’s personal office. Access to information will be restricted to specified personnel.
       6. False claims
          1. A whistleblower who makes a report that is not in good faith, i.e. was done primarily with malice to damage another person or the organisation, is subject to disciplinary action, including termination of employment, working relationship, or other legal means to protect the reputation of RidPest, its directors and its employees
       7. Obstruction of Investigation
          1. Any person who obstructs an investigation of a whistleblowing report is subject to disciplinary action, including, but not limited to, the termination of contract and removal of directorship.
       8. Request for information
          1. On request, the IM will provide the following information to the whistleblower:
             1. The name of the individual(s) handling the investigation.
             2. Progress on, and relevant timelines of the investigation in so far as it does not impact the investigation.
             3. Final decision made on the case.
       9. Further recourse
          1. Should a whistleblower be dissatisfied with the progress and/or final decision made on the reported case, he/she may report this concern to relevant enforcement authorities such as the Malaysian Anti-Corruption Commission or the police.
    6. Whistleblowing Procedures
       1. Whistleblowing disclosures may be made via the following methods:
          1. Website
          2. E-mail
          3. Mail
          4. Telephone
          5. SMS
          6. Face to face with the owner/CEO or IM
    7. See Whistleblowing Information Form for types of information to be provided by the whistleblower as well as the contact details for the above
    8. All whistleblowing reports will be channelled to the IM who will decide on whether the report relates to a corruption incident(s)
    9. Non-corruption reports will be passed along to HR and other relevant HODs, and other internal procedures will take place.
    10. For reports relating to corruption:
        1. A new file on the report will be opened and all details recorded by the IM
        2. The owner/CEO will be notified of the report when a new file is opened and after preliminary investigation is completed by the IM
        3. The file, without the identity of the whistleblower, will be passed to relevant HR staff to conduct Domestic Inquiry.
        4. Once the Domestic Inquiry is finalised, the owner/CEO will decide on the next course of action which include:
           1. Involvement of MACC
           2. Involvement of police
           3. Sanctions:
              1. Written warning
              2. Forfeiture of emoluments
              3. Deferment of salary increase
              4. Demotion of salary
              5. Demotion
              6. Dismissal
           4. Transfer of staff members involved in corrupt act
           5. No further action taken (if report is unsubstantiated)
        5. The owner/CEO is to be notified of all findings as well as the final decision on course of action

Integrity Manager Terms Of Reference
Essential Characteristics Of An Integrity Manager:

• A person of integrity, with a personal commitment to anti-corruption.
• Demonstrates an understanding of the challenge of dealing with corruption, and the issues specific to the business and industry.
• Financially secure, with no history of drug abuse, alcoholism, gambling or serious debt.
• Determined, not easily swayed or intimidated.
• A high level of diligence, attention to detail, and the ability to see an item of work completed regardless of obstacles and challenges.
• Team working ability, able to work across multiple departments and obtain buy-in.
• Good communication skills.
• To keep up to date on developments in integrity tools and methodologies.
• Has direct reporting line to the owner/CEO and/or the BOD

Advantages Of The Role

• Change management experience
• Business analysis skills
• Information gathering, analysis & recommendations
• Process mapping & design
• Working experience in the following areas:
• Procurement
• Sales
• Finance
• Training skills and experience
• Policy formulation experience
• An understanding of integrity tools such as Integrity Pacts, Whistleblowing and Monitoring procedures

Integrity Manager Role Description

1. To manage the Integrity Team
2. To support the Board of Directors in implementing, maintaining and reviewing the Corporate Integrity System (CIS)
3. To support the Integrity Committee or equivalent in implementing, maintaining and reviewing the Corporate Integrity System (CIS)
4. To implement and maintain Corporate Integrity System (CIS):
   1. Establish and manage the integrity infrastructure:
      1. Whistleblowing structure
      2. Declaration of Interest & Asset Declaration forms
      3. Risk management process
      4. Integrity policies and procedures
      5. Other items as required
   2. Handle incidents relating to corruption provided by the whistleblowing process, authorities such as the Malaysian Anti-Corruption Commission (MACC), and the media.
      1. Log and record the incident
      2. Notify the relevant committees that an incident has taken place
      3. Work with HR, Internal and External Auditor to investigate corruption incidents
      4. Work with HR, Legal and other departments to implement sanctions
   3. Manage the Risk Register for corruption incidents
      1. Identify, record and assess corruption risks
      2. Identify mitigation measures and recommend them to the Integrity Committee or equivalent
      3. Implement mitigation measures and provide support to HODs as required
   4. Manage the recording and approvals process for gifts, hospitality, charitable donations, political donations and other risk areas procedures
      1. Maintain data records on risk areas
      2. Manage procedure for approval
      3. Provide guidance and advice to staff
   5. Conduct integrity audits, working with the internal audit department
      1. Identify risk areas
      2. Introduce measures
      3. Monitor effectiveness and propose improvements
   6. Manage the declaration of interest declaration forms process and documentation.
      1. Provide the forms and reminders to all relevant staff
      2. Keep the forms in a highly secure environment for reference
      3. Assess declaration of interest forms to identify risk areas
      4. Liaise with purchasing committee or equivalent to ensure declaration of interest are noted and appropriate measures taken to safeguard the process
   7. Raise awareness and handle internal and external communications regarding integrity
      1. Conduct briefings to staff and contractors
      2. Conduct training for key staff
      3. Manage awareness campaigns
   8. Liaise with anti-corruption institutions such as MACC and TI-M to draw on their expertise in combating corruption
   9. Identify areas for improvement and enhancement and develop proposals for implementation
   10. Conduct research on anti-corruption best practices and attend training sessions, conferences and industry forums.
   11. Ensure all matters relating to integrity compliance are adhered to

Whistleblowing Contact Details