This Policy sets out the responsibilities of Merchantrade Group and those who work for us with regard to observing and upholding our zero-tolerance position on bribery and corruption in accordance with the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act 2009”) and the laws of Malaysia

Merchantrade Asia Sdn Bhd (Merchantrade), requires Directors/Board members, all employees & third parties to comply with the Anti-Bribery & Corruption Policy (ABC Policy) to ensure that Merchantrade’s business activities are conducted in compliance with all applicable legal and regulatory requirements relating to anti-bribery and corruption.

1. Merchantrade is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Merchantrade has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
2. Merchantrade will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate.
3. Definition of corruption: Corruption is the act of abusing entrusted power for private gain by giving or receiving of any gratification or reward in the form of cash or in-kind of high value for performing a task.
4. Definition of bribery: Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
5. Employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of Malaysia) must not engage in any form of bribery & corruption. The policy also applies to Directors / Board members, and/or Officers at any level.
6. If any employee breaches the ABC policy, they will face disciplinary actions, including dismissal for gross misconduct. Merchantrade reserves the right to terminate relationships with any third parties for breaches of the ABC Policy.
7. Merchantrade has put in place the Whistleblowing Policy as a safe and accessible channel to report any acts of bribery and corruption involving the company’s personnel in a confidential manner that protects the whistleblower from any reprisals. Reports may be submitted on a confidential basis or anonymously via the following channels:
   • Post: Post Box G23, Ground Floor, Block A, Damansara Intan, No 1, Jalan SS20/27, 47400 Petaling Jaya, Selangor Darul Ehsan, or
   • E-mail: [email protected]

Note: This is an abridged version of Merchantrade’s Anti Bribery & Corruption Policy