40 ENRA GROUP BERHAD ANNUAL REPORT 2024 Sustainability Report (Cont’d) • ANTI-CORRUPTION ENRA upholds a stringent zero-tolerance stance against corruption within the organisation, its business divisions, and across the supply chain. This commitment aligns seamlessly with Bursa Malaysia's Main Market Listing Requirements, which mandate that publicly listed companies refrain from any actions that contravene Section 17A of the Malaysian Anti-Corruption Commission (Amendment) Act 2018. Anti-corruption measures hold significant importance for the Group, as any confirmed incident of bribery or corruption could have detrimental consequences for the Group's reputation and may even lead to criminal prosecution. Weaknesses in the Group's anti-corruption governance could hinder efforts to prevent or monitor existing corruption cases, potentially giving rise to further instances of corruption. The Board sets the standard for the Group's unwavering zero-tolerance stance against all forms of bribery, corruption, and unethical behaviour within the organisation. Collaborating closely with the ARMSC and the Group Compliance and Governance Department (“GCGD”), the Board provides oversight, guidance, and leadership at the highest level of decision-making in the development and implementation of anti-bribery and anti-corruption policies and practices. Prior to FYE 2022, the Legal Department served as the primary organisational driver for anti-corruption initiatives within the Group. However, this role has now been assumed by the GCGD. In FYE 2021, the Board approved the ENRA Anti-Corruption Policy, which was subsequently rolled out across the Group, taking effect from 1 June 2020. This measure was undertaken to reinforce the Group's commitment to combating corruption within its own operations and throughout the supply chain. The AntiCorruption Policy explicitly stipulates that organisations are liable if found involved in corruption, bribery, or related misconduct. This liability extends to individuals and entities within the Group, encompassing directors, managers, employees, workers, and third-party partners. Individuals or groups discovered to have breached the Anti-Corruption Policy or engaged in any of the stipulated acts of bribery and corruption will be subjected to stringent disciplinary actions. These actions may involve suspension from employment or permanent termination of employment. Legal proceedings may also be pursued, if deemed appropriate. Anti-corruption data is verified by the GCGD. There were zero confirmed incidences/cases of corruption or Anti-Corruption Policy violations at ENRA in FYE 2024. The Anti-Corruption Policy may undergo revisions as necessary to align with any legislative changes or updates in ENRA's governance. The full Anti-Corruption Policy can be read on the Group’s website at www.enra.my. • GAP ANALYSIS ON ANTI-CORRUPTION RISK AND CONTROL In FYE 2020, the GCGD conducted a gap analysis exercise on anti-corruption controls to identify areas requiring improvement. Closing these gaps involved several initiatives, including the formulation and dissemination of the Anti-Corruption Policy in FYE 2021 across the entire Group and its personnel. Procedures for addressing anti-corruption risks have subsequently undergone enhancements throughout the Group. The GCGD conducts assessments of potential corruption risks through the Quarterly Enterprise Risk Management Process and the semi-annual Code of Business Conduct Questionnaire declaration. The Group intends to conduct regular gap assessments in the future, led by the GCGD, to ensure a thorough evaluation of potential integrity vulnerabilities and corruption risks within ENRA. This proactive approach extends to the Group's value chain as well. • GIFTS, ENTERTAINMENT & HOSPITALITY The Group has taken additional steps to enhance its anti-corruption measures by implementing the Gifts and Hospitality Reporting Guidelines on 30 April 2021. These guidelines offer transparent guidance to all employees members on what constitutes acceptable behaviour concerning the giving and receiving of gifts and hospitality. This guideline is to be read together with the Anti-Corruption Policy & Procedure and applies to each Director, employee, and person associated with the Group. Persons associated with the Group are prohibited from soliciting, receiving, offering, promising or providing gifts, hospitality or entertainment, directly or indirectly, as this may give rise to a conflict of interest position. However, limited exceptions can be made in specific circumstances. Full details of ENRA’s policy on the provision and / or receipt of gifts / entertainment and hospitality and any related procedures can be found in the Group’s Anti-Corruption Policy and Gifts and Hospitality which are available on the Group’s website at www.enra.my.
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